2000/01/21-STATE OF UTAH'S RESPONSE TO THE APPLICANT'S ...
Transcript of 2000/01/21-STATE OF UTAH'S RESPONSE TO THE APPLICANT'S ...
UNITED STATES OF AMERICANUCLEAR REGULATORY COMMISSION
f- i- r j - I I 1 1- l- jI- I- - I l1
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 00 JIAN 27 P 3 53
)In the Matter of ) Docket No 72-22-ISFSI Al-
PRIVATE FUEL STORAGE LLC ) ASLBP No 97-732-02-ISFSI(Independent Spent Fuel )
Storage Installation) ) January 21 2000
STATE OF UTAHS RESPONSE TO THE APPLICANTS MOTION FORSUMMARY DISPOSITION OF UTAH CONTENTION GG - FAILURE TO
DEMONSTRATE CASK-PAD STABILITY DURING SEISMIC EVENT FORTRANSTOR CASKS
On December 30 1999 the Applicant filed a Motion for Summary Disposition of
Utah Contention GG (PFS Motion) supported by the Declaration of Dr Alan Soler
The State now files this Response to the Applicants Motion supported by a Statement of
Material and Disputed Facts and the Declaration of Dr Farhang Ostadan (Ostadan
Dec)
BACKGROUND
As admitted Utah Contention GG states
The Applicant has failed to demonstrate that the TranStor storage casksand the pads will remain stable during a seismic event and thus theapplication does not satisfy 10 CFR sectsect 72122(b)(2) and 72128(a) inthat Sierra Nuclears consultant Advent Engineering Services Inc used anonconservative nonsliding cask tipover analysis that did not considerthat the coefficient of friction may vary over the surface of the pad and didnot consider the shift from the static case to the kinetic case whenconsidering momentum of the moving casks
Private Fuel Storage LLC (Independent Spent Fuel Storage Installation) LBP-98-7 47
NRC 142 257 (1998) This contention was filed in response to the TranStor Storage
2 0 -lb
71
Cask Seismic Stability Analysis for PFS Site July 24 1997 (Private Utility Fuel
Storage Project Cask Seismic Tipover Analysis prepared for Sierra Nuclear Corporation
by Advent Engineering Services Inc (hereinafter Advent Report)) PFS admits that
the Advent Report analytically pinned the cask to the pad thereby failing to consider
potential cask sliding during seismic activity PFS Motion at 2 In other words the
Advent Report simply analyzed whether the TranStor cask would tip over during seismic
activity See Advent Report
PFS has now submitted a revised analysis of the stability of the TranStor cask
which considers potential sliding at different coefficients of friction See PFS Motion at
3 and PFSF Site-Specific Cask Stability Analysis for the TranStor Storage Casks
(September 23 1999) attached as Exhibit 2 to Declaration of Dr Alan Soler (hereinafter
Revised Analysis) However the Revised Analysis still fails to consider coefficients of
friction reasonably expected to occur during seismic activity and does not demonstrate
that the casks will remain stable under those conditions
STANDARD OF REVIEW
Pursuant to 10 CFR sect 2740 a party is entitled to summary disposition if there is
no genuine issue as to any material fact and the party is entitled to a decision as a
matter of law The burden of proving entitlement to summary disposition is on the
movant Advanced Medical Systems Inc (One Factory Row Geneva Ohio 44041)
CLI-93-22 38 NRC 98 102 (1993) Moreover the evidence submitted must be
construed in favor of the party in opposition thereto who receives the benefit of any
favorable inferences that can be drawn Sequoyah Fuels Corp and General Atomics
2
Corp (Gore Oklahoma Site Decontamination and Decommissioning Funding) LBP-94-
17 39NRC 359 361 aff-dCLI-94-11 40 NRC 55(1994) If there is anypossibility that
a litigable issue of fact exists or any doubt as to whether the parties should be permitted
or required to proceed further the motion must be denied See General Electric Co (GE
Morris Operation Spent Fuel Storage Facility) LBP-82-14 15 NRC 530 532 (1982)
ARGUMENT
PFS argues that Utah Contention GG is now moot because the Revised Analysis
considers a range of coefficients of friction See PFS Motion at 3 First the State
disputes that the Revised Analysis considers a relevant range of coefficients of friction
Moreover the Revised Analysis still fails to demonstrate the stability of the TranStor
casks during seismic activity because the Analysis erroneously assumes that the pads are
rigid under dynamic loading conditions and that dynamic forces will not affect the
coefficient of friction See Ostadan Dec IT 7-8 Furthermore the Revised Analysis does
not consider the effects of cold bonding and its effect on the coefficient of friction Thus
the Revised Analysis fails to satisfy the concerns raised by Utah Contention GG Second
Dr Ostadans Declaration raises several issues of material fact which renders Summary
Disposition procedures inapplicable PFSs Motion therefore should be denied and
Utah Contention GG should proceed to hearing
I Utah Contention GG Is Not Moot Because the Applicants Revised Analysis IsBased on Erroneous Assumptions and It Fails to Consider a Relevant Range ofCoefficients of Friction
An applicant for an ISFSI license must demonstrate that structures systems and
components important to safety are designed to withstand natural phenomena including
3
earthquakes as well as accident conditions See 10 CFR sectsect 72122(b)(2) and
72128(a) In Utah Contention GG the State asserted that the analysis performed by
Advent Engineering Services Inc inadequately analyzed the stability of the TranStor
storage cask system during seismic activity See 47 NRC 142 257 (Utah Contention GG
as admitted) PFS claims that Utah Contention GG only concerns the coefficient of
friction See PFS Motion at 2 n1 The State disputes this point However even under
the assumption that Utah Contention GG only concerns the coefficient of friction and its
effects on the stability of TranStor storage casks the Revised Analysis fails to correctly
consider variable coefficients of friction See Ostadan Dec mpara 9 10
The Revised Analysis assumes that the contact surface between the bottom of the
cask and top of the foundation will remain intact after loading the casks on the pad and
during seismic excitation which effectively implies that the concrete pad is rigid under
both static and dynamic loading See id para 7 Therefore the Revised Analysis used a
uniform coefficient of friction at 02 and then again at 08 to analyze the stability of the
TranStor cask See PFS Motion at 6-7 The Revised Analysis is inaccurate in several
aspects First the Revised Analysis assumes that the pad will remain rigid under cask
loading See id T 7 Because the Revised Analysis assumed the pad was rigid the
analysis failed to consider the effects of frictional forces which cause the coefficient of
friction to vary across the surface of the pad Under this assumption the Revised
Analysis employs simple frictional elements at the contact points between the casks and
the pad See id However the pad will deform when subjected to cask loading See id
8 Consequently the use of simple frictional elements at the contact points in the Revised
4
Analysis will not accurately predict the stability of the casks under dynamic conditions
because the coefficient of friction will depend on frictional forces See id The high and
low coefficients of friction employed in the Revised Analysis will not bound the actual
frictional behavior because the Revised Analysis is based on the assumption that
frictional forces will not affect the coefficient of friction See id para 9
Second the Revised Analysis did not take into account the effects of cold
bonding See id para 10 This condition between the cask and the pad is not covered by the
highest coefficient of friction (08) See id see also Revised Analysis If a cold bond
were broken during seismic activity it could cause the contact points between the casks
and pad to be nonuniform See Ostadan Dec 1 10 Since the Revised Analysis only
considered simple friction elements see id para 7 the actual frictional forces may fall
outside the high bound of the coefficients of friction used in the Revised Analysis In
other words if cold bonding were to occur the coefficient of friction would be higher
than 08 (the highest value analyzed in the Revised Analysis) See Ostadan Dec para 10
While the Revised Analysis attempts to account for coefficients of friction over
the surface of the pad the Revised Analysis fails to account for the actual variations in
coefficients of friction Moreover the use of 08 does not bound the highest coefficient
of friction such that may occur during cold bonding Therefore the Revised Analysis
does not render Utah Contention GG moot
II PFS Is Not Entitled to Summary Disposition Because There Are Genuine Issuesof Material Facts
A movant is only entitled to summary disposition when there are no genuine
5
issues of material facts See Advanced Medical Systems Inc (One Factory Row
Geneva Ohio 44041) CLI-93-22 38 NRC 98 102 (1993) PFS claims that there are no
genuine issues of material fact See PFS Motion at 5 However Dr Ostadans
Declaration raises several issues regarding the accuracy of the Revised Analysis thereby
rendering summary disposition inapplicable
Dr Ostadan after reviewing the Revised Analysis has concluded that the
Analysis is incorrect and fails to consider the actual coefficients of friction that would
occur during seismic activity See Ostadan Dec mpara 7-10 Specifically there is a genuine
issue as to whether the pad will remain rigid under cask loading See id m 7-8
Moreover there is a dispute as to whether simple frictional elements applied at
coefficients of friction of 02 and 08 bound the actual behavior of the casks under
dynamic loading Compare PFS Motion at 6-7 with Ostadans Dec mpara 9-10 Apparently
Dr Soler relies on the assumption that the coefficient of friction is independent of
frictional forces See Soler Declaration in Support of Applicants December 27 1999
Response to Utahs Motion to Compel Applicant to Respond to States Fifth Set of
Discovery Requests para 10 The State disputes the fact that the coefficient of friction is
independent of frictional force and dynamic loading See Ostadans Dec para 8 Since the
coefficient of friction is dependent on dynamic forces under the circumstances it is
material to the issue of whether the Revised Analysis considers the variability of
coefficients of friction over the pad
All of these disputes directly relate to the accuracy of the Revised Analysis and
the variability of the coefficient of friction over the pad These factual disputes taken in
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the light most favorable to the State entitle the State to go forward with Contention GG
Therefore the PFS Motion must be denied
DATED this 21 st day of January 2000
Respec submitted
Denise Chancellor Assistant Attorney GeneralFred G Nelson Assistant Attorney GeneralConnie Nakahara Special Assistant Attorney GeneralDiane Curran Special Assistant Attorney GeneralLaura Lockhart Assistant Attorney GeneralAttorneys for State of Utah Utah Attorney Generals Office160 East 300 South 5th Floor PO Box 140873Salt Lake City UT 84114-0873Telephone (801) 366-0286 Fax (801) 366-0292
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CERTIFICATE OF SERVICE -1 -i 1 - - -- -
J 1i G 7 - I t L i__ _ tJI i I F4
I hereby certify that a copy of STATE OF UTAHS RESPONSE TO THEgt00 JN 27 7 53
APPLICANTS MOTION FOR SUMMARY DISPOSITION OF UTAH CONTENTION
GG - FAILURE TO DEMONSTRATE CASK-PAD STABILITY DURING SEISMIC
EVENT FOR TRANSTOR CASKS was served on the persons listed below by electronic
mail (unless otherwise noted) with conforming copies by United States mail first class
this 21 st day of January 2000
Emile L Julian Assistant forRulemakings and Adjudications
Rulemaking amp Adjudication StaffSecretary of the CommissionU S Nuclear Regulatory CommissionWashington DC 20555E-mail hearingdocket~nrcgov(original and two copies)
G Paul Bollwerk HI ChairmanAdministrative JudgeAtomic Safety and Licensing BoardU S Nuclear Regulatory CommissionWashington DC 20555E-Mail gpb~nrcgov
Dr Jerry R KlineAdministrative JudgeAtomic Safety and Licensing BoardU S Nuclear Regulatory CommissionWashington DC 20555E-Mail jrk2nrcgovE-Mail kjerrygerolscom
Dr Peter S LamAdministrative JudgeAtomic Safety and Licensing BoardU S Nuclear Regulatory CommissionWashington DC 20555E-Mail psl~nrcgov
Sherwin E Turk EsqCatherine L Marco EsqOffice of the General Counsel
Mail Stop O-15-B-18US Nuclear Regulatory CommissionWashington DC 20555E-Mail setgnrcgovE-Mail clm~nrcgov
Jay E Silberg EsqErnest L Blake Jr EsqPaul A Gaukler EsqShaw Pittman Potts amp Trowbridge2300 N Street N WWashington DC 20037-8007E-Mail JaySilberg~shawpittmancomE-Mail ernestblakegshawpittmancomE-Mail paulgaukler~shawpittmancom
8
John Paul Kennedy Sr Esq1385 Yale AvenueSalt Lake City Utah 84105E-Mail john~kennedysorg
Joro Walker EsqLand and Water Fund of the Rockies2056 East 3300 South Street Suite ISalt Lake City Utah 84109E-Mail joro61inconnectcom
Danny Quintana EsqDanny Quintana amp Associates PC68 South Main Street Suite 600Salt Lake City Utah 84101E-Mail quintana~xmissioncom
James M CutchinAtomic Safety and Licensing Board PanelUS Nuclear Regulatory CommissionWashington DC 20555-0001E-Mail jmc3nrcgov(electronic copy only)
Office of the Commission AppellateAdjudication
Mail Stop 014-G-15U S Nuclear Regulatory CommissionWashington DC 20555
Assistant Attorney GeneralState of Utah
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UNITED STATES OF AMERICANUCLEAR REGULATORY COMMISSION
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)_In the Matter of ) Docket No 72-22-ISFSI
)PRIVATE FUEL STORAGE LLC ) ASLBP No 97-732-02-ISFSI(Independent Spent Fuel )
Storage Installation) ) January 21 2000
STATE OF UTAHS STATEMENT OF DISPUTEDAND RELEVANT MATERIAL FACTS FOR UTAH CONTENTION GG
1 The State disputes PFS Material Fact No 10 in that 08 does not bound the highestcoefficient of friction expected to occur Ostadan Dec at para 10
2 The cask and the concrete pad may develop cold bonding Ostadan Dec para 10 Thecold bonding causes a contact condition between the cask and the pad that is notcovered by the coefficient of friction 08 Ostadan Dec at para 10
3 The cold bonding may break during seismic shaking in a nonuniform pattern causinga nonuniform contact condition between the cask and the pad Ostadan Dec at para 10The coefficient of friction would not remain constant
4 The State disputes PFS Material Fact No 11 in that the two coefficients of friction02 and 08 do not effectively bracket any variation in the coefficient of friction overthe surface of the pad Ostadan Dec at IT 7 8 9 11
5 The coefficient of friction between the cask and the concrete pad is not uniformacross the surface of the cask Ostadan Dec at T 9
6 The concrete pad will not behave as a rigid surface under either static or dynamicloading Ostadan Dec at para 8
7 Due to the flexible nature of the pad the coefficient of friction will be dependentupon frictional forces Ostadan Dec at para 8
8 The contact surface between the bottom of the cask and the top of the foundation padwill not remain intact during cask loading or seismic movement Ostadan Dec at para 8
UNITED STATES OF AMERICA NUCLEAR REGULA TORY COMMISSION
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
) In the Matter of ) Docket No 72-22-ISFSI
) PRNATE FUEL STORAGE LLC ) ASLBP No 97-732-02-ISFSI (Independent Spent Fuel )
Storage Installation) ) January 21 2000
DECLARATION OF FARHANG OSTADAN PH D
I FARHANG OSTADAN hereby declare under penalty ofperjury and pursuant to 28
USC sect 1746 that
1 I hold a PhD in civil engineering from the University of
California at Berkeley My curriculum vitae listing my qualifications experience
training and publications has already been filed in this proceeding See Exhibit No2 of
the States Motion to Compel Applicant to Respond to States Fifth Set of Discovery
Requests dated December 20 1999
2 I have fifteen years experience in dynamic analysis and seismic
safety evaluation of above and underground structures and subsurface materials I coshy
developed and implemented SASSI a system for seismic soil-structure interaction
analysis currently in use by the industry worldwide I also developed a method for
liquefaction hazard analysis currently in use for critical facilities in the United States
3 I have participated in seismic studies and review of numerous
nuclear structures including Diablo Canyon Nuclear Station and the NRCEPRllarge
scale seismic experiment in Lotung Taiwan I have published numerous papers in the
area of soil structure interaction and seismic design
4 I have read the materials filed by PFS in support of its Motion for
Summary Disposition of Contention GG including the Safety Analysis Report for the
TranStor Storage Cask System rev B the TranS tor Storage Cask Seismic Stability
Analysis for PFS Site July 24 1997 (Private Utility Fuel Storage Project Cask Seismic
Tipover Analysis prepared for Sierra Nuclear Corporation by Advent Engineering
Services Inc (hereinafter Advent Report)) the PFSF Site Specific Cask Stability
Analysis for the TranStor Storage Cask September 23 1999 and the TranStor
Dynamic Response to 2000 Year Return Seismic Event Holtec Report No HI-99229S
I am familiar with the circumstances and materials in this case as they relate to
Contention GG including PFSs Safety Analysis Report I am also familiar with and have
reviewed the documents that PFS has provided to the State ofUtah concerning Utah
Contention GG PFSs responses to Discovery Requests submitted by the State and
PFSs responses to the NRC Staffs Requests for Additional Information
5 The Applicant has performed a series of simple nonlinear time
history analyses in which the interaction between the cask and the foundation pad is
modeled by frictional elements The coefficient offuction was changed in successive
analyses from 020 to 080 Soler Dec Sum Disp at ~ 9
6 Dr Alan Soler states that the coefficient of friction is a property
2
associated with a contact point between two surfaces and the value of the coefficient is
dependent on the characteristics of the two materials at the interface contact point Soler
Dec Sum Disp at ~ 7 In a declaration supporting the Applicants Response to State of
Utahs Motion to Compel Applicant to Respond to States Fifth Set of Discovery
Requests Dr Solar claims that the coefficient of friction is independent of the friction
forces Solar Dec Resp Mo Compel at ~ 10 However the coefficient of friction is
only independent of friction forces under certain circumstances
7 In justifying that the coefficient of friction is independent of
friction forces Dr Soler must assume that the contact surface between the bottom of the
cask and top of the foundation will remain intact after loading the casks on the pad and
during the seismic excitation which effectively implies that the concrete pad is rigid under
both static and dynamic loading This assumption led the Applicant to the simplifying
assumption for the dynamic analysis of the cask by using simple frictional elements at the
contact points
8 However using the Applicants parameters including the
coefficient ofthe subgrade reaction of275 kipsft3 (SAR Rev 8 at 26-35) and the pad
dimensions (SAR Rev 8 at 26-87) and the relationship described in Foundation
Analysis and Design Fourth edition Joseph Bowels McGraw Hill Company 1988
Section 97 hereto attached as Exhibit A to distinguish a flexible versus a rigid mat I
have calculated that the pad will not be rigid and in fact will deform when subjected to
cask loading Thus Dr Solers assumption that the cask pad is rigid is incorrect
3
Moreover because the pad is flexible the coefficient of friction is dependent on friction
forces and will be affected at the contact points between the cask and the pad
9 Under dynamic loading the dynamic properties of a flexible pad
are different from those of a rigid pad I The flexible behavior of the foundation pad will
amplify under the inertia of the casks on the pad Thus the coefficient of friction will not
be constant across the pad and the Applicants analysis of uniform coefficient of friction
will not bound the actual behavior of the casks and the pad
10 It is also possible that the casks on the pad could develop a cold
bonding over time The cold bonding causes a contact condition between the cask and
the pad that is not covered by the highest coefficient of friction used by the Applicant
Additionally the effect of the cold bonding is not necessarily the same as the hinge
condition that the Applicant assumed in the previous Advent analysis 2 The bonding may
break during seismic shaking in a nonuniform pattern depending on the contact stresses
causing a nonuniform contact condition between the cask and the pad
11 Within the context of Contention GG and the modeling technique
used by the Applicant and considering the realistic and flexible behavior of the pad under
1 An excellent comparison of the dynamic properties of rigid versus flexible foundation is presented by Iguchi and Luco in Dynamic response ofFlexible Rectangular Foundations on an Elastic Halfspace Journal of Earthquake Engineering and Structural dynamics 1981 Vol 9
2 The Advent Report assumed that the cask was analytically pinned at one edge and did not consider the coefficients of friction Soler Dec Sum Disp at ~ 4
4
P0011001
BOI j56C292 p C06
ootil the statIc find dy11amic loading il is my opinion (hili the 1joltec 2000 analysis relied
llpon by lhe Aptllicant till falls to considcrvarilltiOli of coelilcicm Qf friction over the
surfllce ofthc pad and the shift from static case to kinetic cnsc
12 This Declaration hils been prepared in 5UPPO( of the State of
Utahs RLlsponse to Applicants M~llion for Summary Disposition ()(Contcntion Utuh
GG and Lhe Slates nccomp~nying Statement of Msnelial ract~ and is trile and correct to
the best M my knowledge nnd beief
DATED thi~ January 21 ~woo
ATTACHMENT A
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IlUUJ 110 t1l70
FOUNDA11Ul~ UVJVVIJ
ANALYSIS Al1J)
DESIGN Fourth Edition
Joseph E Bowles PE SE Ctmsulril1 ilIgilllerStJjrwtlre C(msullam
~1If1IrIfill~J c~mlllt(r SI(flllrt Poritl lIIimljs
McGraw-lUll Publishina Company New York St Louu SAIl Frlllciseo lullkllllld HOlloW Canebullbull
HlIMbllrs Utbon Loodon MdrW Mtldco Milan MQflJnzl New Delhi OItlaho1na Ciqo Pan Son 111amp11
sro Plo SlngporI Syc1llY Tokyo TorqllQ
I
V 1 _ v
410 FouNDATION ANALVSlS AND DI5KlN
97 CLASSICAL SOLllTION OF BEAM ON ELASTIC FOlJNDAnON
When tlexur1 rigidity oCthe [aotin iii taken into accounl a solution is used that is based on some fonn of a heam on an elEl~tic (oundaLlon This may be of the classical Winkler solution of about 1861 in which the founchulon is considered as a bed of sprins (Winkler round ation) or a nnllgteement procedure of the nex section
The classical solutions being of closed ronn are not as ~ncra in application as the finite-clement merhod The basic differential equal ion is (see Fie 9-10)
pound1 dXlJy q - k~y (9-1l)
JAN -20 OO(THU) 1018
SPJ(IAL morlNOS owp BIlAS ON f)Imc ~(lIlNIgtIlTIONS 411
TABLE)2 Cloted-form Bolldons of infinite beam on Iseric fOlndlltiQn (Fig 9middot1011)
-VI M=TBu
Q -VIC
CflrJCllnrnltuli 101141 QI tilnln Moment III CDnllllf
MJl J -k- Bu dcllcclion
P M =rrcbullbull
-I -MeQ=-1gt Q= -2- A shear
Z
The A B C IiLPd D COtlfficienLS are
A =- o~) + silll)
BJgtt c-lmiddot ~in AX
Cl~ - middot(cosx - sin ltx)
1J1~ -u COampx
where k kB In solvin the equations a variable is inLroduced
bull 4 (iii )Iii -Jill or
TabJe 9middot2 Sives the closedmiddotfonn solution of t e basic differential equations for scveralloadingll shown in Fig 9-10 ulilizing the Winkler concept It is convCJliell~ to express the trigonometric portion of the solutions sepannely as in tbe bottom of Table 9middot2
He~enyi (1946) developed equations for a load at any point along a beam (see Fig 9middot10b) mea~ured from the len end as rallows
JAN -20 00 (THU) 1018 BEl TEL415 768 4898 p 004005
412 FOlNDAT10N ANALYSIS NI) OESION
k = kiP Hncludes cffic or BJ
-----) -----0 cUM [b) Finite length beam cn elUlic
(oundation ---
--~----~gt~~-r--IJ~lt~--~~~M I ~~
Moment curve
Ii ---shy ~ Q ---~~
~ Shear curve
ta) Infillitc Icnlh beam an an elude rOllndatlan
FIGUDE 1)10 Beam on eillstic roundaticm
Y k~ (sinh ~l_ sjJl2 AL) 2 cosh AX cosu (sinh U cos la cosh)b
-ilin L cosh )(J cos lb) + (cosh It-X sin lx
+ sinh 1x cos tx) [sinh U (sin)a cosh 1b - cos ttl sinh lb)
+~j )L (sinh lQ cos)b - cosh ia sin Ah)J) (9middot12)
M a t ( hl ~ l AL) 2 sin AX sin h (sinh tL cos ~ cosb lb _ SIn I - SUI
- Sill U cosh AU WS ~iJ - l~osh 1( sinlx - sillh lx cos AX)
x [sinh)L (sin ta cosb 1b - cos )a sinh )b)
+sill )L sinh l cos ib - coshit sin ib)J (9-13)
-- TEL415 768 4898 JAN -20 OOTHUI 1018 BEl bull __ ~ bullbull nM~1gt UN ElAT1C rOU~tgtAIr)NS 411
x (sinh L cos AQ cosh Jb - sin iL cosh AQ CQS )h)
+ sinh Ax sin i( [sinh L (sin la cosh b shy cos 1Q sinh lb)
+ sin )L (liinh )a etlS h shy cosh AQ sin )b)]
The equation far the slope eof the beam at any point is not pre$ented is of little value in the design of a footing The value of x to use in the equa from the end o the beam to the point ror which the deOection moment or desired If x is less than the distance use the equations lS given and meaSUf x from C Ifx is largdf than a replace a with b in the equations and measure x from D (Fig 9middottOb) These equations may be rewritten as
Y=~A M=S and QPCk ~A
whllre the coeffioients A B and C are the values or the hyperbolic and trigonometric remainder of Eqs (9-12) to (9middot14)
It has been proposed that one could u~e U previously defined to determine if a foundation should be analyzed 011 the basis of the conventional rigid procedure Or as a beam on an elastic foundation
Rigi members (bending not influenced much by k)
(bending bcavity localized)
e 8l1tbor has found the above criteria 0 1 e app leation bocause of the infiuence or number of loads and their locations on the member
The classical solution presented here has several distinct disadviulluges over the finj[~middotelement solution presented i~ the next section such as
I Assumes weipoundhtless beam (but weight wUl be a factor when footing tends to stlparate from the soil)
2 Difficult to remove soil effect when footing tends to separate [rom soil 3 Difficult [0 account for boundary conditions orknown rotation or deflection at
seleCted points 4 Difficult to apply multiple types or loads to a foolina S Difficult to chanse footins properties of I D and B 6 Difficult to allow for change in subgrade reaclion along fOOling
Although tbe disltdvaruages are substantial iome engineeri prefer the classical beatll-onelaslic-foundation approacb over discrete element analyses Rarely the classical approach may be a better model than a discrete elemetn analysis so it is worthwhile to have access to ilii5 method of solution
P 005005
Cask Seismic Stability Analysis for PFS Site July 24 1997 (Private Utility Fuel
Storage Project Cask Seismic Tipover Analysis prepared for Sierra Nuclear Corporation
by Advent Engineering Services Inc (hereinafter Advent Report)) PFS admits that
the Advent Report analytically pinned the cask to the pad thereby failing to consider
potential cask sliding during seismic activity PFS Motion at 2 In other words the
Advent Report simply analyzed whether the TranStor cask would tip over during seismic
activity See Advent Report
PFS has now submitted a revised analysis of the stability of the TranStor cask
which considers potential sliding at different coefficients of friction See PFS Motion at
3 and PFSF Site-Specific Cask Stability Analysis for the TranStor Storage Casks
(September 23 1999) attached as Exhibit 2 to Declaration of Dr Alan Soler (hereinafter
Revised Analysis) However the Revised Analysis still fails to consider coefficients of
friction reasonably expected to occur during seismic activity and does not demonstrate
that the casks will remain stable under those conditions
STANDARD OF REVIEW
Pursuant to 10 CFR sect 2740 a party is entitled to summary disposition if there is
no genuine issue as to any material fact and the party is entitled to a decision as a
matter of law The burden of proving entitlement to summary disposition is on the
movant Advanced Medical Systems Inc (One Factory Row Geneva Ohio 44041)
CLI-93-22 38 NRC 98 102 (1993) Moreover the evidence submitted must be
construed in favor of the party in opposition thereto who receives the benefit of any
favorable inferences that can be drawn Sequoyah Fuels Corp and General Atomics
2
Corp (Gore Oklahoma Site Decontamination and Decommissioning Funding) LBP-94-
17 39NRC 359 361 aff-dCLI-94-11 40 NRC 55(1994) If there is anypossibility that
a litigable issue of fact exists or any doubt as to whether the parties should be permitted
or required to proceed further the motion must be denied See General Electric Co (GE
Morris Operation Spent Fuel Storage Facility) LBP-82-14 15 NRC 530 532 (1982)
ARGUMENT
PFS argues that Utah Contention GG is now moot because the Revised Analysis
considers a range of coefficients of friction See PFS Motion at 3 First the State
disputes that the Revised Analysis considers a relevant range of coefficients of friction
Moreover the Revised Analysis still fails to demonstrate the stability of the TranStor
casks during seismic activity because the Analysis erroneously assumes that the pads are
rigid under dynamic loading conditions and that dynamic forces will not affect the
coefficient of friction See Ostadan Dec IT 7-8 Furthermore the Revised Analysis does
not consider the effects of cold bonding and its effect on the coefficient of friction Thus
the Revised Analysis fails to satisfy the concerns raised by Utah Contention GG Second
Dr Ostadans Declaration raises several issues of material fact which renders Summary
Disposition procedures inapplicable PFSs Motion therefore should be denied and
Utah Contention GG should proceed to hearing
I Utah Contention GG Is Not Moot Because the Applicants Revised Analysis IsBased on Erroneous Assumptions and It Fails to Consider a Relevant Range ofCoefficients of Friction
An applicant for an ISFSI license must demonstrate that structures systems and
components important to safety are designed to withstand natural phenomena including
3
earthquakes as well as accident conditions See 10 CFR sectsect 72122(b)(2) and
72128(a) In Utah Contention GG the State asserted that the analysis performed by
Advent Engineering Services Inc inadequately analyzed the stability of the TranStor
storage cask system during seismic activity See 47 NRC 142 257 (Utah Contention GG
as admitted) PFS claims that Utah Contention GG only concerns the coefficient of
friction See PFS Motion at 2 n1 The State disputes this point However even under
the assumption that Utah Contention GG only concerns the coefficient of friction and its
effects on the stability of TranStor storage casks the Revised Analysis fails to correctly
consider variable coefficients of friction See Ostadan Dec mpara 9 10
The Revised Analysis assumes that the contact surface between the bottom of the
cask and top of the foundation will remain intact after loading the casks on the pad and
during seismic excitation which effectively implies that the concrete pad is rigid under
both static and dynamic loading See id para 7 Therefore the Revised Analysis used a
uniform coefficient of friction at 02 and then again at 08 to analyze the stability of the
TranStor cask See PFS Motion at 6-7 The Revised Analysis is inaccurate in several
aspects First the Revised Analysis assumes that the pad will remain rigid under cask
loading See id T 7 Because the Revised Analysis assumed the pad was rigid the
analysis failed to consider the effects of frictional forces which cause the coefficient of
friction to vary across the surface of the pad Under this assumption the Revised
Analysis employs simple frictional elements at the contact points between the casks and
the pad See id However the pad will deform when subjected to cask loading See id
8 Consequently the use of simple frictional elements at the contact points in the Revised
4
Analysis will not accurately predict the stability of the casks under dynamic conditions
because the coefficient of friction will depend on frictional forces See id The high and
low coefficients of friction employed in the Revised Analysis will not bound the actual
frictional behavior because the Revised Analysis is based on the assumption that
frictional forces will not affect the coefficient of friction See id para 9
Second the Revised Analysis did not take into account the effects of cold
bonding See id para 10 This condition between the cask and the pad is not covered by the
highest coefficient of friction (08) See id see also Revised Analysis If a cold bond
were broken during seismic activity it could cause the contact points between the casks
and pad to be nonuniform See Ostadan Dec 1 10 Since the Revised Analysis only
considered simple friction elements see id para 7 the actual frictional forces may fall
outside the high bound of the coefficients of friction used in the Revised Analysis In
other words if cold bonding were to occur the coefficient of friction would be higher
than 08 (the highest value analyzed in the Revised Analysis) See Ostadan Dec para 10
While the Revised Analysis attempts to account for coefficients of friction over
the surface of the pad the Revised Analysis fails to account for the actual variations in
coefficients of friction Moreover the use of 08 does not bound the highest coefficient
of friction such that may occur during cold bonding Therefore the Revised Analysis
does not render Utah Contention GG moot
II PFS Is Not Entitled to Summary Disposition Because There Are Genuine Issuesof Material Facts
A movant is only entitled to summary disposition when there are no genuine
5
issues of material facts See Advanced Medical Systems Inc (One Factory Row
Geneva Ohio 44041) CLI-93-22 38 NRC 98 102 (1993) PFS claims that there are no
genuine issues of material fact See PFS Motion at 5 However Dr Ostadans
Declaration raises several issues regarding the accuracy of the Revised Analysis thereby
rendering summary disposition inapplicable
Dr Ostadan after reviewing the Revised Analysis has concluded that the
Analysis is incorrect and fails to consider the actual coefficients of friction that would
occur during seismic activity See Ostadan Dec mpara 7-10 Specifically there is a genuine
issue as to whether the pad will remain rigid under cask loading See id m 7-8
Moreover there is a dispute as to whether simple frictional elements applied at
coefficients of friction of 02 and 08 bound the actual behavior of the casks under
dynamic loading Compare PFS Motion at 6-7 with Ostadans Dec mpara 9-10 Apparently
Dr Soler relies on the assumption that the coefficient of friction is independent of
frictional forces See Soler Declaration in Support of Applicants December 27 1999
Response to Utahs Motion to Compel Applicant to Respond to States Fifth Set of
Discovery Requests para 10 The State disputes the fact that the coefficient of friction is
independent of frictional force and dynamic loading See Ostadans Dec para 8 Since the
coefficient of friction is dependent on dynamic forces under the circumstances it is
material to the issue of whether the Revised Analysis considers the variability of
coefficients of friction over the pad
All of these disputes directly relate to the accuracy of the Revised Analysis and
the variability of the coefficient of friction over the pad These factual disputes taken in
6
the light most favorable to the State entitle the State to go forward with Contention GG
Therefore the PFS Motion must be denied
DATED this 21 st day of January 2000
Respec submitted
Denise Chancellor Assistant Attorney GeneralFred G Nelson Assistant Attorney GeneralConnie Nakahara Special Assistant Attorney GeneralDiane Curran Special Assistant Attorney GeneralLaura Lockhart Assistant Attorney GeneralAttorneys for State of Utah Utah Attorney Generals Office160 East 300 South 5th Floor PO Box 140873Salt Lake City UT 84114-0873Telephone (801) 366-0286 Fax (801) 366-0292
7
CERTIFICATE OF SERVICE -1 -i 1 - - -- -
J 1i G 7 - I t L i__ _ tJI i I F4
I hereby certify that a copy of STATE OF UTAHS RESPONSE TO THEgt00 JN 27 7 53
APPLICANTS MOTION FOR SUMMARY DISPOSITION OF UTAH CONTENTION
GG - FAILURE TO DEMONSTRATE CASK-PAD STABILITY DURING SEISMIC
EVENT FOR TRANSTOR CASKS was served on the persons listed below by electronic
mail (unless otherwise noted) with conforming copies by United States mail first class
this 21 st day of January 2000
Emile L Julian Assistant forRulemakings and Adjudications
Rulemaking amp Adjudication StaffSecretary of the CommissionU S Nuclear Regulatory CommissionWashington DC 20555E-mail hearingdocket~nrcgov(original and two copies)
G Paul Bollwerk HI ChairmanAdministrative JudgeAtomic Safety and Licensing BoardU S Nuclear Regulatory CommissionWashington DC 20555E-Mail gpb~nrcgov
Dr Jerry R KlineAdministrative JudgeAtomic Safety and Licensing BoardU S Nuclear Regulatory CommissionWashington DC 20555E-Mail jrk2nrcgovE-Mail kjerrygerolscom
Dr Peter S LamAdministrative JudgeAtomic Safety and Licensing BoardU S Nuclear Regulatory CommissionWashington DC 20555E-Mail psl~nrcgov
Sherwin E Turk EsqCatherine L Marco EsqOffice of the General Counsel
Mail Stop O-15-B-18US Nuclear Regulatory CommissionWashington DC 20555E-Mail setgnrcgovE-Mail clm~nrcgov
Jay E Silberg EsqErnest L Blake Jr EsqPaul A Gaukler EsqShaw Pittman Potts amp Trowbridge2300 N Street N WWashington DC 20037-8007E-Mail JaySilberg~shawpittmancomE-Mail ernestblakegshawpittmancomE-Mail paulgaukler~shawpittmancom
8
John Paul Kennedy Sr Esq1385 Yale AvenueSalt Lake City Utah 84105E-Mail john~kennedysorg
Joro Walker EsqLand and Water Fund of the Rockies2056 East 3300 South Street Suite ISalt Lake City Utah 84109E-Mail joro61inconnectcom
Danny Quintana EsqDanny Quintana amp Associates PC68 South Main Street Suite 600Salt Lake City Utah 84101E-Mail quintana~xmissioncom
James M CutchinAtomic Safety and Licensing Board PanelUS Nuclear Regulatory CommissionWashington DC 20555-0001E-Mail jmc3nrcgov(electronic copy only)
Office of the Commission AppellateAdjudication
Mail Stop 014-G-15U S Nuclear Regulatory CommissionWashington DC 20555
Assistant Attorney GeneralState of Utah
9
UNITED STATES OF AMERICANUCLEAR REGULATORY COMMISSION
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)_In the Matter of ) Docket No 72-22-ISFSI
)PRIVATE FUEL STORAGE LLC ) ASLBP No 97-732-02-ISFSI(Independent Spent Fuel )
Storage Installation) ) January 21 2000
STATE OF UTAHS STATEMENT OF DISPUTEDAND RELEVANT MATERIAL FACTS FOR UTAH CONTENTION GG
1 The State disputes PFS Material Fact No 10 in that 08 does not bound the highestcoefficient of friction expected to occur Ostadan Dec at para 10
2 The cask and the concrete pad may develop cold bonding Ostadan Dec para 10 Thecold bonding causes a contact condition between the cask and the pad that is notcovered by the coefficient of friction 08 Ostadan Dec at para 10
3 The cold bonding may break during seismic shaking in a nonuniform pattern causinga nonuniform contact condition between the cask and the pad Ostadan Dec at para 10The coefficient of friction would not remain constant
4 The State disputes PFS Material Fact No 11 in that the two coefficients of friction02 and 08 do not effectively bracket any variation in the coefficient of friction overthe surface of the pad Ostadan Dec at IT 7 8 9 11
5 The coefficient of friction between the cask and the concrete pad is not uniformacross the surface of the cask Ostadan Dec at T 9
6 The concrete pad will not behave as a rigid surface under either static or dynamicloading Ostadan Dec at para 8
7 Due to the flexible nature of the pad the coefficient of friction will be dependentupon frictional forces Ostadan Dec at para 8
8 The contact surface between the bottom of the cask and the top of the foundation padwill not remain intact during cask loading or seismic movement Ostadan Dec at para 8
UNITED STATES OF AMERICA NUCLEAR REGULA TORY COMMISSION
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
) In the Matter of ) Docket No 72-22-ISFSI
) PRNATE FUEL STORAGE LLC ) ASLBP No 97-732-02-ISFSI (Independent Spent Fuel )
Storage Installation) ) January 21 2000
DECLARATION OF FARHANG OSTADAN PH D
I FARHANG OSTADAN hereby declare under penalty ofperjury and pursuant to 28
USC sect 1746 that
1 I hold a PhD in civil engineering from the University of
California at Berkeley My curriculum vitae listing my qualifications experience
training and publications has already been filed in this proceeding See Exhibit No2 of
the States Motion to Compel Applicant to Respond to States Fifth Set of Discovery
Requests dated December 20 1999
2 I have fifteen years experience in dynamic analysis and seismic
safety evaluation of above and underground structures and subsurface materials I coshy
developed and implemented SASSI a system for seismic soil-structure interaction
analysis currently in use by the industry worldwide I also developed a method for
liquefaction hazard analysis currently in use for critical facilities in the United States
3 I have participated in seismic studies and review of numerous
nuclear structures including Diablo Canyon Nuclear Station and the NRCEPRllarge
scale seismic experiment in Lotung Taiwan I have published numerous papers in the
area of soil structure interaction and seismic design
4 I have read the materials filed by PFS in support of its Motion for
Summary Disposition of Contention GG including the Safety Analysis Report for the
TranStor Storage Cask System rev B the TranS tor Storage Cask Seismic Stability
Analysis for PFS Site July 24 1997 (Private Utility Fuel Storage Project Cask Seismic
Tipover Analysis prepared for Sierra Nuclear Corporation by Advent Engineering
Services Inc (hereinafter Advent Report)) the PFSF Site Specific Cask Stability
Analysis for the TranStor Storage Cask September 23 1999 and the TranStor
Dynamic Response to 2000 Year Return Seismic Event Holtec Report No HI-99229S
I am familiar with the circumstances and materials in this case as they relate to
Contention GG including PFSs Safety Analysis Report I am also familiar with and have
reviewed the documents that PFS has provided to the State ofUtah concerning Utah
Contention GG PFSs responses to Discovery Requests submitted by the State and
PFSs responses to the NRC Staffs Requests for Additional Information
5 The Applicant has performed a series of simple nonlinear time
history analyses in which the interaction between the cask and the foundation pad is
modeled by frictional elements The coefficient offuction was changed in successive
analyses from 020 to 080 Soler Dec Sum Disp at ~ 9
6 Dr Alan Soler states that the coefficient of friction is a property
2
associated with a contact point between two surfaces and the value of the coefficient is
dependent on the characteristics of the two materials at the interface contact point Soler
Dec Sum Disp at ~ 7 In a declaration supporting the Applicants Response to State of
Utahs Motion to Compel Applicant to Respond to States Fifth Set of Discovery
Requests Dr Solar claims that the coefficient of friction is independent of the friction
forces Solar Dec Resp Mo Compel at ~ 10 However the coefficient of friction is
only independent of friction forces under certain circumstances
7 In justifying that the coefficient of friction is independent of
friction forces Dr Soler must assume that the contact surface between the bottom of the
cask and top of the foundation will remain intact after loading the casks on the pad and
during the seismic excitation which effectively implies that the concrete pad is rigid under
both static and dynamic loading This assumption led the Applicant to the simplifying
assumption for the dynamic analysis of the cask by using simple frictional elements at the
contact points
8 However using the Applicants parameters including the
coefficient ofthe subgrade reaction of275 kipsft3 (SAR Rev 8 at 26-35) and the pad
dimensions (SAR Rev 8 at 26-87) and the relationship described in Foundation
Analysis and Design Fourth edition Joseph Bowels McGraw Hill Company 1988
Section 97 hereto attached as Exhibit A to distinguish a flexible versus a rigid mat I
have calculated that the pad will not be rigid and in fact will deform when subjected to
cask loading Thus Dr Solers assumption that the cask pad is rigid is incorrect
3
Moreover because the pad is flexible the coefficient of friction is dependent on friction
forces and will be affected at the contact points between the cask and the pad
9 Under dynamic loading the dynamic properties of a flexible pad
are different from those of a rigid pad I The flexible behavior of the foundation pad will
amplify under the inertia of the casks on the pad Thus the coefficient of friction will not
be constant across the pad and the Applicants analysis of uniform coefficient of friction
will not bound the actual behavior of the casks and the pad
10 It is also possible that the casks on the pad could develop a cold
bonding over time The cold bonding causes a contact condition between the cask and
the pad that is not covered by the highest coefficient of friction used by the Applicant
Additionally the effect of the cold bonding is not necessarily the same as the hinge
condition that the Applicant assumed in the previous Advent analysis 2 The bonding may
break during seismic shaking in a nonuniform pattern depending on the contact stresses
causing a nonuniform contact condition between the cask and the pad
11 Within the context of Contention GG and the modeling technique
used by the Applicant and considering the realistic and flexible behavior of the pad under
1 An excellent comparison of the dynamic properties of rigid versus flexible foundation is presented by Iguchi and Luco in Dynamic response ofFlexible Rectangular Foundations on an Elastic Halfspace Journal of Earthquake Engineering and Structural dynamics 1981 Vol 9
2 The Advent Report assumed that the cask was analytically pinned at one edge and did not consider the coefficients of friction Soler Dec Sum Disp at ~ 4
4
P0011001
BOI j56C292 p C06
ootil the statIc find dy11amic loading il is my opinion (hili the 1joltec 2000 analysis relied
llpon by lhe Aptllicant till falls to considcrvarilltiOli of coelilcicm Qf friction over the
surfllce ofthc pad and the shift from static case to kinetic cnsc
12 This Declaration hils been prepared in 5UPPO( of the State of
Utahs RLlsponse to Applicants M~llion for Summary Disposition ()(Contcntion Utuh
GG and Lhe Slates nccomp~nying Statement of Msnelial ract~ and is trile and correct to
the best M my knowledge nnd beief
DATED thi~ January 21 ~woo
ATTACHMENT A
LlLJI
IlUUJ 110 t1l70
FOUNDA11Ul~ UVJVVIJ
ANALYSIS Al1J)
DESIGN Fourth Edition
Joseph E Bowles PE SE Ctmsulril1 ilIgilllerStJjrwtlre C(msullam
~1If1IrIfill~J c~mlllt(r SI(flllrt Poritl lIIimljs
McGraw-lUll Publishina Company New York St Louu SAIl Frlllciseo lullkllllld HOlloW Canebullbull
HlIMbllrs Utbon Loodon MdrW Mtldco Milan MQflJnzl New Delhi OItlaho1na Ciqo Pan Son 111amp11
sro Plo SlngporI Syc1llY Tokyo TorqllQ
I
V 1 _ v
410 FouNDATION ANALVSlS AND DI5KlN
97 CLASSICAL SOLllTION OF BEAM ON ELASTIC FOlJNDAnON
When tlexur1 rigidity oCthe [aotin iii taken into accounl a solution is used that is based on some fonn of a heam on an elEl~tic (oundaLlon This may be of the classical Winkler solution of about 1861 in which the founchulon is considered as a bed of sprins (Winkler round ation) or a nnllgteement procedure of the nex section
The classical solutions being of closed ronn are not as ~ncra in application as the finite-clement merhod The basic differential equal ion is (see Fie 9-10)
pound1 dXlJy q - k~y (9-1l)
JAN -20 OO(THU) 1018
SPJ(IAL morlNOS owp BIlAS ON f)Imc ~(lIlNIgtIlTIONS 411
TABLE)2 Cloted-form Bolldons of infinite beam on Iseric fOlndlltiQn (Fig 9middot1011)
-VI M=TBu
Q -VIC
CflrJCllnrnltuli 101141 QI tilnln Moment III CDnllllf
MJl J -k- Bu dcllcclion
P M =rrcbullbull
-I -MeQ=-1gt Q= -2- A shear
Z
The A B C IiLPd D COtlfficienLS are
A =- o~) + silll)
BJgtt c-lmiddot ~in AX
Cl~ - middot(cosx - sin ltx)
1J1~ -u COampx
where k kB In solvin the equations a variable is inLroduced
bull 4 (iii )Iii -Jill or
TabJe 9middot2 Sives the closedmiddotfonn solution of t e basic differential equations for scveralloadingll shown in Fig 9-10 ulilizing the Winkler concept It is convCJliell~ to express the trigonometric portion of the solutions sepannely as in tbe bottom of Table 9middot2
He~enyi (1946) developed equations for a load at any point along a beam (see Fig 9middot10b) mea~ured from the len end as rallows
JAN -20 00 (THU) 1018 BEl TEL415 768 4898 p 004005
412 FOlNDAT10N ANALYSIS NI) OESION
k = kiP Hncludes cffic or BJ
-----) -----0 cUM [b) Finite length beam cn elUlic
(oundation ---
--~----~gt~~-r--IJ~lt~--~~~M I ~~
Moment curve
Ii ---shy ~ Q ---~~
~ Shear curve
ta) Infillitc Icnlh beam an an elude rOllndatlan
FIGUDE 1)10 Beam on eillstic roundaticm
Y k~ (sinh ~l_ sjJl2 AL) 2 cosh AX cosu (sinh U cos la cosh)b
-ilin L cosh )(J cos lb) + (cosh It-X sin lx
+ sinh 1x cos tx) [sinh U (sin)a cosh 1b - cos ttl sinh lb)
+~j )L (sinh lQ cos)b - cosh ia sin Ah)J) (9middot12)
M a t ( hl ~ l AL) 2 sin AX sin h (sinh tL cos ~ cosb lb _ SIn I - SUI
- Sill U cosh AU WS ~iJ - l~osh 1( sinlx - sillh lx cos AX)
x [sinh)L (sin ta cosb 1b - cos )a sinh )b)
+sill )L sinh l cos ib - coshit sin ib)J (9-13)
-- TEL415 768 4898 JAN -20 OOTHUI 1018 BEl bull __ ~ bullbull nM~1gt UN ElAT1C rOU~tgtAIr)NS 411
x (sinh L cos AQ cosh Jb - sin iL cosh AQ CQS )h)
+ sinh Ax sin i( [sinh L (sin la cosh b shy cos 1Q sinh lb)
+ sin )L (liinh )a etlS h shy cosh AQ sin )b)]
The equation far the slope eof the beam at any point is not pre$ented is of little value in the design of a footing The value of x to use in the equa from the end o the beam to the point ror which the deOection moment or desired If x is less than the distance use the equations lS given and meaSUf x from C Ifx is largdf than a replace a with b in the equations and measure x from D (Fig 9middottOb) These equations may be rewritten as
Y=~A M=S and QPCk ~A
whllre the coeffioients A B and C are the values or the hyperbolic and trigonometric remainder of Eqs (9-12) to (9middot14)
It has been proposed that one could u~e U previously defined to determine if a foundation should be analyzed 011 the basis of the conventional rigid procedure Or as a beam on an elastic foundation
Rigi members (bending not influenced much by k)
(bending bcavity localized)
e 8l1tbor has found the above criteria 0 1 e app leation bocause of the infiuence or number of loads and their locations on the member
The classical solution presented here has several distinct disadviulluges over the finj[~middotelement solution presented i~ the next section such as
I Assumes weipoundhtless beam (but weight wUl be a factor when footing tends to stlparate from the soil)
2 Difficult to remove soil effect when footing tends to separate [rom soil 3 Difficult [0 account for boundary conditions orknown rotation or deflection at
seleCted points 4 Difficult to apply multiple types or loads to a foolina S Difficult to chanse footins properties of I D and B 6 Difficult to allow for change in subgrade reaclion along fOOling
Although tbe disltdvaruages are substantial iome engineeri prefer the classical beatll-onelaslic-foundation approacb over discrete element analyses Rarely the classical approach may be a better model than a discrete elemetn analysis so it is worthwhile to have access to ilii5 method of solution
P 005005
Corp (Gore Oklahoma Site Decontamination and Decommissioning Funding) LBP-94-
17 39NRC 359 361 aff-dCLI-94-11 40 NRC 55(1994) If there is anypossibility that
a litigable issue of fact exists or any doubt as to whether the parties should be permitted
or required to proceed further the motion must be denied See General Electric Co (GE
Morris Operation Spent Fuel Storage Facility) LBP-82-14 15 NRC 530 532 (1982)
ARGUMENT
PFS argues that Utah Contention GG is now moot because the Revised Analysis
considers a range of coefficients of friction See PFS Motion at 3 First the State
disputes that the Revised Analysis considers a relevant range of coefficients of friction
Moreover the Revised Analysis still fails to demonstrate the stability of the TranStor
casks during seismic activity because the Analysis erroneously assumes that the pads are
rigid under dynamic loading conditions and that dynamic forces will not affect the
coefficient of friction See Ostadan Dec IT 7-8 Furthermore the Revised Analysis does
not consider the effects of cold bonding and its effect on the coefficient of friction Thus
the Revised Analysis fails to satisfy the concerns raised by Utah Contention GG Second
Dr Ostadans Declaration raises several issues of material fact which renders Summary
Disposition procedures inapplicable PFSs Motion therefore should be denied and
Utah Contention GG should proceed to hearing
I Utah Contention GG Is Not Moot Because the Applicants Revised Analysis IsBased on Erroneous Assumptions and It Fails to Consider a Relevant Range ofCoefficients of Friction
An applicant for an ISFSI license must demonstrate that structures systems and
components important to safety are designed to withstand natural phenomena including
3
earthquakes as well as accident conditions See 10 CFR sectsect 72122(b)(2) and
72128(a) In Utah Contention GG the State asserted that the analysis performed by
Advent Engineering Services Inc inadequately analyzed the stability of the TranStor
storage cask system during seismic activity See 47 NRC 142 257 (Utah Contention GG
as admitted) PFS claims that Utah Contention GG only concerns the coefficient of
friction See PFS Motion at 2 n1 The State disputes this point However even under
the assumption that Utah Contention GG only concerns the coefficient of friction and its
effects on the stability of TranStor storage casks the Revised Analysis fails to correctly
consider variable coefficients of friction See Ostadan Dec mpara 9 10
The Revised Analysis assumes that the contact surface between the bottom of the
cask and top of the foundation will remain intact after loading the casks on the pad and
during seismic excitation which effectively implies that the concrete pad is rigid under
both static and dynamic loading See id para 7 Therefore the Revised Analysis used a
uniform coefficient of friction at 02 and then again at 08 to analyze the stability of the
TranStor cask See PFS Motion at 6-7 The Revised Analysis is inaccurate in several
aspects First the Revised Analysis assumes that the pad will remain rigid under cask
loading See id T 7 Because the Revised Analysis assumed the pad was rigid the
analysis failed to consider the effects of frictional forces which cause the coefficient of
friction to vary across the surface of the pad Under this assumption the Revised
Analysis employs simple frictional elements at the contact points between the casks and
the pad See id However the pad will deform when subjected to cask loading See id
8 Consequently the use of simple frictional elements at the contact points in the Revised
4
Analysis will not accurately predict the stability of the casks under dynamic conditions
because the coefficient of friction will depend on frictional forces See id The high and
low coefficients of friction employed in the Revised Analysis will not bound the actual
frictional behavior because the Revised Analysis is based on the assumption that
frictional forces will not affect the coefficient of friction See id para 9
Second the Revised Analysis did not take into account the effects of cold
bonding See id para 10 This condition between the cask and the pad is not covered by the
highest coefficient of friction (08) See id see also Revised Analysis If a cold bond
were broken during seismic activity it could cause the contact points between the casks
and pad to be nonuniform See Ostadan Dec 1 10 Since the Revised Analysis only
considered simple friction elements see id para 7 the actual frictional forces may fall
outside the high bound of the coefficients of friction used in the Revised Analysis In
other words if cold bonding were to occur the coefficient of friction would be higher
than 08 (the highest value analyzed in the Revised Analysis) See Ostadan Dec para 10
While the Revised Analysis attempts to account for coefficients of friction over
the surface of the pad the Revised Analysis fails to account for the actual variations in
coefficients of friction Moreover the use of 08 does not bound the highest coefficient
of friction such that may occur during cold bonding Therefore the Revised Analysis
does not render Utah Contention GG moot
II PFS Is Not Entitled to Summary Disposition Because There Are Genuine Issuesof Material Facts
A movant is only entitled to summary disposition when there are no genuine
5
issues of material facts See Advanced Medical Systems Inc (One Factory Row
Geneva Ohio 44041) CLI-93-22 38 NRC 98 102 (1993) PFS claims that there are no
genuine issues of material fact See PFS Motion at 5 However Dr Ostadans
Declaration raises several issues regarding the accuracy of the Revised Analysis thereby
rendering summary disposition inapplicable
Dr Ostadan after reviewing the Revised Analysis has concluded that the
Analysis is incorrect and fails to consider the actual coefficients of friction that would
occur during seismic activity See Ostadan Dec mpara 7-10 Specifically there is a genuine
issue as to whether the pad will remain rigid under cask loading See id m 7-8
Moreover there is a dispute as to whether simple frictional elements applied at
coefficients of friction of 02 and 08 bound the actual behavior of the casks under
dynamic loading Compare PFS Motion at 6-7 with Ostadans Dec mpara 9-10 Apparently
Dr Soler relies on the assumption that the coefficient of friction is independent of
frictional forces See Soler Declaration in Support of Applicants December 27 1999
Response to Utahs Motion to Compel Applicant to Respond to States Fifth Set of
Discovery Requests para 10 The State disputes the fact that the coefficient of friction is
independent of frictional force and dynamic loading See Ostadans Dec para 8 Since the
coefficient of friction is dependent on dynamic forces under the circumstances it is
material to the issue of whether the Revised Analysis considers the variability of
coefficients of friction over the pad
All of these disputes directly relate to the accuracy of the Revised Analysis and
the variability of the coefficient of friction over the pad These factual disputes taken in
6
the light most favorable to the State entitle the State to go forward with Contention GG
Therefore the PFS Motion must be denied
DATED this 21 st day of January 2000
Respec submitted
Denise Chancellor Assistant Attorney GeneralFred G Nelson Assistant Attorney GeneralConnie Nakahara Special Assistant Attorney GeneralDiane Curran Special Assistant Attorney GeneralLaura Lockhart Assistant Attorney GeneralAttorneys for State of Utah Utah Attorney Generals Office160 East 300 South 5th Floor PO Box 140873Salt Lake City UT 84114-0873Telephone (801) 366-0286 Fax (801) 366-0292
7
CERTIFICATE OF SERVICE -1 -i 1 - - -- -
J 1i G 7 - I t L i__ _ tJI i I F4
I hereby certify that a copy of STATE OF UTAHS RESPONSE TO THEgt00 JN 27 7 53
APPLICANTS MOTION FOR SUMMARY DISPOSITION OF UTAH CONTENTION
GG - FAILURE TO DEMONSTRATE CASK-PAD STABILITY DURING SEISMIC
EVENT FOR TRANSTOR CASKS was served on the persons listed below by electronic
mail (unless otherwise noted) with conforming copies by United States mail first class
this 21 st day of January 2000
Emile L Julian Assistant forRulemakings and Adjudications
Rulemaking amp Adjudication StaffSecretary of the CommissionU S Nuclear Regulatory CommissionWashington DC 20555E-mail hearingdocket~nrcgov(original and two copies)
G Paul Bollwerk HI ChairmanAdministrative JudgeAtomic Safety and Licensing BoardU S Nuclear Regulatory CommissionWashington DC 20555E-Mail gpb~nrcgov
Dr Jerry R KlineAdministrative JudgeAtomic Safety and Licensing BoardU S Nuclear Regulatory CommissionWashington DC 20555E-Mail jrk2nrcgovE-Mail kjerrygerolscom
Dr Peter S LamAdministrative JudgeAtomic Safety and Licensing BoardU S Nuclear Regulatory CommissionWashington DC 20555E-Mail psl~nrcgov
Sherwin E Turk EsqCatherine L Marco EsqOffice of the General Counsel
Mail Stop O-15-B-18US Nuclear Regulatory CommissionWashington DC 20555E-Mail setgnrcgovE-Mail clm~nrcgov
Jay E Silberg EsqErnest L Blake Jr EsqPaul A Gaukler EsqShaw Pittman Potts amp Trowbridge2300 N Street N WWashington DC 20037-8007E-Mail JaySilberg~shawpittmancomE-Mail ernestblakegshawpittmancomE-Mail paulgaukler~shawpittmancom
8
John Paul Kennedy Sr Esq1385 Yale AvenueSalt Lake City Utah 84105E-Mail john~kennedysorg
Joro Walker EsqLand and Water Fund of the Rockies2056 East 3300 South Street Suite ISalt Lake City Utah 84109E-Mail joro61inconnectcom
Danny Quintana EsqDanny Quintana amp Associates PC68 South Main Street Suite 600Salt Lake City Utah 84101E-Mail quintana~xmissioncom
James M CutchinAtomic Safety and Licensing Board PanelUS Nuclear Regulatory CommissionWashington DC 20555-0001E-Mail jmc3nrcgov(electronic copy only)
Office of the Commission AppellateAdjudication
Mail Stop 014-G-15U S Nuclear Regulatory CommissionWashington DC 20555
Assistant Attorney GeneralState of Utah
9
UNITED STATES OF AMERICANUCLEAR REGULATORY COMMISSION
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)_In the Matter of ) Docket No 72-22-ISFSI
)PRIVATE FUEL STORAGE LLC ) ASLBP No 97-732-02-ISFSI(Independent Spent Fuel )
Storage Installation) ) January 21 2000
STATE OF UTAHS STATEMENT OF DISPUTEDAND RELEVANT MATERIAL FACTS FOR UTAH CONTENTION GG
1 The State disputes PFS Material Fact No 10 in that 08 does not bound the highestcoefficient of friction expected to occur Ostadan Dec at para 10
2 The cask and the concrete pad may develop cold bonding Ostadan Dec para 10 Thecold bonding causes a contact condition between the cask and the pad that is notcovered by the coefficient of friction 08 Ostadan Dec at para 10
3 The cold bonding may break during seismic shaking in a nonuniform pattern causinga nonuniform contact condition between the cask and the pad Ostadan Dec at para 10The coefficient of friction would not remain constant
4 The State disputes PFS Material Fact No 11 in that the two coefficients of friction02 and 08 do not effectively bracket any variation in the coefficient of friction overthe surface of the pad Ostadan Dec at IT 7 8 9 11
5 The coefficient of friction between the cask and the concrete pad is not uniformacross the surface of the cask Ostadan Dec at T 9
6 The concrete pad will not behave as a rigid surface under either static or dynamicloading Ostadan Dec at para 8
7 Due to the flexible nature of the pad the coefficient of friction will be dependentupon frictional forces Ostadan Dec at para 8
8 The contact surface between the bottom of the cask and the top of the foundation padwill not remain intact during cask loading or seismic movement Ostadan Dec at para 8
UNITED STATES OF AMERICA NUCLEAR REGULA TORY COMMISSION
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
) In the Matter of ) Docket No 72-22-ISFSI
) PRNATE FUEL STORAGE LLC ) ASLBP No 97-732-02-ISFSI (Independent Spent Fuel )
Storage Installation) ) January 21 2000
DECLARATION OF FARHANG OSTADAN PH D
I FARHANG OSTADAN hereby declare under penalty ofperjury and pursuant to 28
USC sect 1746 that
1 I hold a PhD in civil engineering from the University of
California at Berkeley My curriculum vitae listing my qualifications experience
training and publications has already been filed in this proceeding See Exhibit No2 of
the States Motion to Compel Applicant to Respond to States Fifth Set of Discovery
Requests dated December 20 1999
2 I have fifteen years experience in dynamic analysis and seismic
safety evaluation of above and underground structures and subsurface materials I coshy
developed and implemented SASSI a system for seismic soil-structure interaction
analysis currently in use by the industry worldwide I also developed a method for
liquefaction hazard analysis currently in use for critical facilities in the United States
3 I have participated in seismic studies and review of numerous
nuclear structures including Diablo Canyon Nuclear Station and the NRCEPRllarge
scale seismic experiment in Lotung Taiwan I have published numerous papers in the
area of soil structure interaction and seismic design
4 I have read the materials filed by PFS in support of its Motion for
Summary Disposition of Contention GG including the Safety Analysis Report for the
TranStor Storage Cask System rev B the TranS tor Storage Cask Seismic Stability
Analysis for PFS Site July 24 1997 (Private Utility Fuel Storage Project Cask Seismic
Tipover Analysis prepared for Sierra Nuclear Corporation by Advent Engineering
Services Inc (hereinafter Advent Report)) the PFSF Site Specific Cask Stability
Analysis for the TranStor Storage Cask September 23 1999 and the TranStor
Dynamic Response to 2000 Year Return Seismic Event Holtec Report No HI-99229S
I am familiar with the circumstances and materials in this case as they relate to
Contention GG including PFSs Safety Analysis Report I am also familiar with and have
reviewed the documents that PFS has provided to the State ofUtah concerning Utah
Contention GG PFSs responses to Discovery Requests submitted by the State and
PFSs responses to the NRC Staffs Requests for Additional Information
5 The Applicant has performed a series of simple nonlinear time
history analyses in which the interaction between the cask and the foundation pad is
modeled by frictional elements The coefficient offuction was changed in successive
analyses from 020 to 080 Soler Dec Sum Disp at ~ 9
6 Dr Alan Soler states that the coefficient of friction is a property
2
associated with a contact point between two surfaces and the value of the coefficient is
dependent on the characteristics of the two materials at the interface contact point Soler
Dec Sum Disp at ~ 7 In a declaration supporting the Applicants Response to State of
Utahs Motion to Compel Applicant to Respond to States Fifth Set of Discovery
Requests Dr Solar claims that the coefficient of friction is independent of the friction
forces Solar Dec Resp Mo Compel at ~ 10 However the coefficient of friction is
only independent of friction forces under certain circumstances
7 In justifying that the coefficient of friction is independent of
friction forces Dr Soler must assume that the contact surface between the bottom of the
cask and top of the foundation will remain intact after loading the casks on the pad and
during the seismic excitation which effectively implies that the concrete pad is rigid under
both static and dynamic loading This assumption led the Applicant to the simplifying
assumption for the dynamic analysis of the cask by using simple frictional elements at the
contact points
8 However using the Applicants parameters including the
coefficient ofthe subgrade reaction of275 kipsft3 (SAR Rev 8 at 26-35) and the pad
dimensions (SAR Rev 8 at 26-87) and the relationship described in Foundation
Analysis and Design Fourth edition Joseph Bowels McGraw Hill Company 1988
Section 97 hereto attached as Exhibit A to distinguish a flexible versus a rigid mat I
have calculated that the pad will not be rigid and in fact will deform when subjected to
cask loading Thus Dr Solers assumption that the cask pad is rigid is incorrect
3
Moreover because the pad is flexible the coefficient of friction is dependent on friction
forces and will be affected at the contact points between the cask and the pad
9 Under dynamic loading the dynamic properties of a flexible pad
are different from those of a rigid pad I The flexible behavior of the foundation pad will
amplify under the inertia of the casks on the pad Thus the coefficient of friction will not
be constant across the pad and the Applicants analysis of uniform coefficient of friction
will not bound the actual behavior of the casks and the pad
10 It is also possible that the casks on the pad could develop a cold
bonding over time The cold bonding causes a contact condition between the cask and
the pad that is not covered by the highest coefficient of friction used by the Applicant
Additionally the effect of the cold bonding is not necessarily the same as the hinge
condition that the Applicant assumed in the previous Advent analysis 2 The bonding may
break during seismic shaking in a nonuniform pattern depending on the contact stresses
causing a nonuniform contact condition between the cask and the pad
11 Within the context of Contention GG and the modeling technique
used by the Applicant and considering the realistic and flexible behavior of the pad under
1 An excellent comparison of the dynamic properties of rigid versus flexible foundation is presented by Iguchi and Luco in Dynamic response ofFlexible Rectangular Foundations on an Elastic Halfspace Journal of Earthquake Engineering and Structural dynamics 1981 Vol 9
2 The Advent Report assumed that the cask was analytically pinned at one edge and did not consider the coefficients of friction Soler Dec Sum Disp at ~ 4
4
P0011001
BOI j56C292 p C06
ootil the statIc find dy11amic loading il is my opinion (hili the 1joltec 2000 analysis relied
llpon by lhe Aptllicant till falls to considcrvarilltiOli of coelilcicm Qf friction over the
surfllce ofthc pad and the shift from static case to kinetic cnsc
12 This Declaration hils been prepared in 5UPPO( of the State of
Utahs RLlsponse to Applicants M~llion for Summary Disposition ()(Contcntion Utuh
GG and Lhe Slates nccomp~nying Statement of Msnelial ract~ and is trile and correct to
the best M my knowledge nnd beief
DATED thi~ January 21 ~woo
ATTACHMENT A
LlLJI
IlUUJ 110 t1l70
FOUNDA11Ul~ UVJVVIJ
ANALYSIS Al1J)
DESIGN Fourth Edition
Joseph E Bowles PE SE Ctmsulril1 ilIgilllerStJjrwtlre C(msullam
~1If1IrIfill~J c~mlllt(r SI(flllrt Poritl lIIimljs
McGraw-lUll Publishina Company New York St Louu SAIl Frlllciseo lullkllllld HOlloW Canebullbull
HlIMbllrs Utbon Loodon MdrW Mtldco Milan MQflJnzl New Delhi OItlaho1na Ciqo Pan Son 111amp11
sro Plo SlngporI Syc1llY Tokyo TorqllQ
I
V 1 _ v
410 FouNDATION ANALVSlS AND DI5KlN
97 CLASSICAL SOLllTION OF BEAM ON ELASTIC FOlJNDAnON
When tlexur1 rigidity oCthe [aotin iii taken into accounl a solution is used that is based on some fonn of a heam on an elEl~tic (oundaLlon This may be of the classical Winkler solution of about 1861 in which the founchulon is considered as a bed of sprins (Winkler round ation) or a nnllgteement procedure of the nex section
The classical solutions being of closed ronn are not as ~ncra in application as the finite-clement merhod The basic differential equal ion is (see Fie 9-10)
pound1 dXlJy q - k~y (9-1l)
JAN -20 OO(THU) 1018
SPJ(IAL morlNOS owp BIlAS ON f)Imc ~(lIlNIgtIlTIONS 411
TABLE)2 Cloted-form Bolldons of infinite beam on Iseric fOlndlltiQn (Fig 9middot1011)
-VI M=TBu
Q -VIC
CflrJCllnrnltuli 101141 QI tilnln Moment III CDnllllf
MJl J -k- Bu dcllcclion
P M =rrcbullbull
-I -MeQ=-1gt Q= -2- A shear
Z
The A B C IiLPd D COtlfficienLS are
A =- o~) + silll)
BJgtt c-lmiddot ~in AX
Cl~ - middot(cosx - sin ltx)
1J1~ -u COampx
where k kB In solvin the equations a variable is inLroduced
bull 4 (iii )Iii -Jill or
TabJe 9middot2 Sives the closedmiddotfonn solution of t e basic differential equations for scveralloadingll shown in Fig 9-10 ulilizing the Winkler concept It is convCJliell~ to express the trigonometric portion of the solutions sepannely as in tbe bottom of Table 9middot2
He~enyi (1946) developed equations for a load at any point along a beam (see Fig 9middot10b) mea~ured from the len end as rallows
JAN -20 00 (THU) 1018 BEl TEL415 768 4898 p 004005
412 FOlNDAT10N ANALYSIS NI) OESION
k = kiP Hncludes cffic or BJ
-----) -----0 cUM [b) Finite length beam cn elUlic
(oundation ---
--~----~gt~~-r--IJ~lt~--~~~M I ~~
Moment curve
Ii ---shy ~ Q ---~~
~ Shear curve
ta) Infillitc Icnlh beam an an elude rOllndatlan
FIGUDE 1)10 Beam on eillstic roundaticm
Y k~ (sinh ~l_ sjJl2 AL) 2 cosh AX cosu (sinh U cos la cosh)b
-ilin L cosh )(J cos lb) + (cosh It-X sin lx
+ sinh 1x cos tx) [sinh U (sin)a cosh 1b - cos ttl sinh lb)
+~j )L (sinh lQ cos)b - cosh ia sin Ah)J) (9middot12)
M a t ( hl ~ l AL) 2 sin AX sin h (sinh tL cos ~ cosb lb _ SIn I - SUI
- Sill U cosh AU WS ~iJ - l~osh 1( sinlx - sillh lx cos AX)
x [sinh)L (sin ta cosb 1b - cos )a sinh )b)
+sill )L sinh l cos ib - coshit sin ib)J (9-13)
-- TEL415 768 4898 JAN -20 OOTHUI 1018 BEl bull __ ~ bullbull nM~1gt UN ElAT1C rOU~tgtAIr)NS 411
x (sinh L cos AQ cosh Jb - sin iL cosh AQ CQS )h)
+ sinh Ax sin i( [sinh L (sin la cosh b shy cos 1Q sinh lb)
+ sin )L (liinh )a etlS h shy cosh AQ sin )b)]
The equation far the slope eof the beam at any point is not pre$ented is of little value in the design of a footing The value of x to use in the equa from the end o the beam to the point ror which the deOection moment or desired If x is less than the distance use the equations lS given and meaSUf x from C Ifx is largdf than a replace a with b in the equations and measure x from D (Fig 9middottOb) These equations may be rewritten as
Y=~A M=S and QPCk ~A
whllre the coeffioients A B and C are the values or the hyperbolic and trigonometric remainder of Eqs (9-12) to (9middot14)
It has been proposed that one could u~e U previously defined to determine if a foundation should be analyzed 011 the basis of the conventional rigid procedure Or as a beam on an elastic foundation
Rigi members (bending not influenced much by k)
(bending bcavity localized)
e 8l1tbor has found the above criteria 0 1 e app leation bocause of the infiuence or number of loads and their locations on the member
The classical solution presented here has several distinct disadviulluges over the finj[~middotelement solution presented i~ the next section such as
I Assumes weipoundhtless beam (but weight wUl be a factor when footing tends to stlparate from the soil)
2 Difficult to remove soil effect when footing tends to separate [rom soil 3 Difficult [0 account for boundary conditions orknown rotation or deflection at
seleCted points 4 Difficult to apply multiple types or loads to a foolina S Difficult to chanse footins properties of I D and B 6 Difficult to allow for change in subgrade reaclion along fOOling
Although tbe disltdvaruages are substantial iome engineeri prefer the classical beatll-onelaslic-foundation approacb over discrete element analyses Rarely the classical approach may be a better model than a discrete elemetn analysis so it is worthwhile to have access to ilii5 method of solution
P 005005
earthquakes as well as accident conditions See 10 CFR sectsect 72122(b)(2) and
72128(a) In Utah Contention GG the State asserted that the analysis performed by
Advent Engineering Services Inc inadequately analyzed the stability of the TranStor
storage cask system during seismic activity See 47 NRC 142 257 (Utah Contention GG
as admitted) PFS claims that Utah Contention GG only concerns the coefficient of
friction See PFS Motion at 2 n1 The State disputes this point However even under
the assumption that Utah Contention GG only concerns the coefficient of friction and its
effects on the stability of TranStor storage casks the Revised Analysis fails to correctly
consider variable coefficients of friction See Ostadan Dec mpara 9 10
The Revised Analysis assumes that the contact surface between the bottom of the
cask and top of the foundation will remain intact after loading the casks on the pad and
during seismic excitation which effectively implies that the concrete pad is rigid under
both static and dynamic loading See id para 7 Therefore the Revised Analysis used a
uniform coefficient of friction at 02 and then again at 08 to analyze the stability of the
TranStor cask See PFS Motion at 6-7 The Revised Analysis is inaccurate in several
aspects First the Revised Analysis assumes that the pad will remain rigid under cask
loading See id T 7 Because the Revised Analysis assumed the pad was rigid the
analysis failed to consider the effects of frictional forces which cause the coefficient of
friction to vary across the surface of the pad Under this assumption the Revised
Analysis employs simple frictional elements at the contact points between the casks and
the pad See id However the pad will deform when subjected to cask loading See id
8 Consequently the use of simple frictional elements at the contact points in the Revised
4
Analysis will not accurately predict the stability of the casks under dynamic conditions
because the coefficient of friction will depend on frictional forces See id The high and
low coefficients of friction employed in the Revised Analysis will not bound the actual
frictional behavior because the Revised Analysis is based on the assumption that
frictional forces will not affect the coefficient of friction See id para 9
Second the Revised Analysis did not take into account the effects of cold
bonding See id para 10 This condition between the cask and the pad is not covered by the
highest coefficient of friction (08) See id see also Revised Analysis If a cold bond
were broken during seismic activity it could cause the contact points between the casks
and pad to be nonuniform See Ostadan Dec 1 10 Since the Revised Analysis only
considered simple friction elements see id para 7 the actual frictional forces may fall
outside the high bound of the coefficients of friction used in the Revised Analysis In
other words if cold bonding were to occur the coefficient of friction would be higher
than 08 (the highest value analyzed in the Revised Analysis) See Ostadan Dec para 10
While the Revised Analysis attempts to account for coefficients of friction over
the surface of the pad the Revised Analysis fails to account for the actual variations in
coefficients of friction Moreover the use of 08 does not bound the highest coefficient
of friction such that may occur during cold bonding Therefore the Revised Analysis
does not render Utah Contention GG moot
II PFS Is Not Entitled to Summary Disposition Because There Are Genuine Issuesof Material Facts
A movant is only entitled to summary disposition when there are no genuine
5
issues of material facts See Advanced Medical Systems Inc (One Factory Row
Geneva Ohio 44041) CLI-93-22 38 NRC 98 102 (1993) PFS claims that there are no
genuine issues of material fact See PFS Motion at 5 However Dr Ostadans
Declaration raises several issues regarding the accuracy of the Revised Analysis thereby
rendering summary disposition inapplicable
Dr Ostadan after reviewing the Revised Analysis has concluded that the
Analysis is incorrect and fails to consider the actual coefficients of friction that would
occur during seismic activity See Ostadan Dec mpara 7-10 Specifically there is a genuine
issue as to whether the pad will remain rigid under cask loading See id m 7-8
Moreover there is a dispute as to whether simple frictional elements applied at
coefficients of friction of 02 and 08 bound the actual behavior of the casks under
dynamic loading Compare PFS Motion at 6-7 with Ostadans Dec mpara 9-10 Apparently
Dr Soler relies on the assumption that the coefficient of friction is independent of
frictional forces See Soler Declaration in Support of Applicants December 27 1999
Response to Utahs Motion to Compel Applicant to Respond to States Fifth Set of
Discovery Requests para 10 The State disputes the fact that the coefficient of friction is
independent of frictional force and dynamic loading See Ostadans Dec para 8 Since the
coefficient of friction is dependent on dynamic forces under the circumstances it is
material to the issue of whether the Revised Analysis considers the variability of
coefficients of friction over the pad
All of these disputes directly relate to the accuracy of the Revised Analysis and
the variability of the coefficient of friction over the pad These factual disputes taken in
6
the light most favorable to the State entitle the State to go forward with Contention GG
Therefore the PFS Motion must be denied
DATED this 21 st day of January 2000
Respec submitted
Denise Chancellor Assistant Attorney GeneralFred G Nelson Assistant Attorney GeneralConnie Nakahara Special Assistant Attorney GeneralDiane Curran Special Assistant Attorney GeneralLaura Lockhart Assistant Attorney GeneralAttorneys for State of Utah Utah Attorney Generals Office160 East 300 South 5th Floor PO Box 140873Salt Lake City UT 84114-0873Telephone (801) 366-0286 Fax (801) 366-0292
7
CERTIFICATE OF SERVICE -1 -i 1 - - -- -
J 1i G 7 - I t L i__ _ tJI i I F4
I hereby certify that a copy of STATE OF UTAHS RESPONSE TO THEgt00 JN 27 7 53
APPLICANTS MOTION FOR SUMMARY DISPOSITION OF UTAH CONTENTION
GG - FAILURE TO DEMONSTRATE CASK-PAD STABILITY DURING SEISMIC
EVENT FOR TRANSTOR CASKS was served on the persons listed below by electronic
mail (unless otherwise noted) with conforming copies by United States mail first class
this 21 st day of January 2000
Emile L Julian Assistant forRulemakings and Adjudications
Rulemaking amp Adjudication StaffSecretary of the CommissionU S Nuclear Regulatory CommissionWashington DC 20555E-mail hearingdocket~nrcgov(original and two copies)
G Paul Bollwerk HI ChairmanAdministrative JudgeAtomic Safety and Licensing BoardU S Nuclear Regulatory CommissionWashington DC 20555E-Mail gpb~nrcgov
Dr Jerry R KlineAdministrative JudgeAtomic Safety and Licensing BoardU S Nuclear Regulatory CommissionWashington DC 20555E-Mail jrk2nrcgovE-Mail kjerrygerolscom
Dr Peter S LamAdministrative JudgeAtomic Safety and Licensing BoardU S Nuclear Regulatory CommissionWashington DC 20555E-Mail psl~nrcgov
Sherwin E Turk EsqCatherine L Marco EsqOffice of the General Counsel
Mail Stop O-15-B-18US Nuclear Regulatory CommissionWashington DC 20555E-Mail setgnrcgovE-Mail clm~nrcgov
Jay E Silberg EsqErnest L Blake Jr EsqPaul A Gaukler EsqShaw Pittman Potts amp Trowbridge2300 N Street N WWashington DC 20037-8007E-Mail JaySilberg~shawpittmancomE-Mail ernestblakegshawpittmancomE-Mail paulgaukler~shawpittmancom
8
John Paul Kennedy Sr Esq1385 Yale AvenueSalt Lake City Utah 84105E-Mail john~kennedysorg
Joro Walker EsqLand and Water Fund of the Rockies2056 East 3300 South Street Suite ISalt Lake City Utah 84109E-Mail joro61inconnectcom
Danny Quintana EsqDanny Quintana amp Associates PC68 South Main Street Suite 600Salt Lake City Utah 84101E-Mail quintana~xmissioncom
James M CutchinAtomic Safety and Licensing Board PanelUS Nuclear Regulatory CommissionWashington DC 20555-0001E-Mail jmc3nrcgov(electronic copy only)
Office of the Commission AppellateAdjudication
Mail Stop 014-G-15U S Nuclear Regulatory CommissionWashington DC 20555
Assistant Attorney GeneralState of Utah
9
UNITED STATES OF AMERICANUCLEAR REGULATORY COMMISSION
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)_In the Matter of ) Docket No 72-22-ISFSI
)PRIVATE FUEL STORAGE LLC ) ASLBP No 97-732-02-ISFSI(Independent Spent Fuel )
Storage Installation) ) January 21 2000
STATE OF UTAHS STATEMENT OF DISPUTEDAND RELEVANT MATERIAL FACTS FOR UTAH CONTENTION GG
1 The State disputes PFS Material Fact No 10 in that 08 does not bound the highestcoefficient of friction expected to occur Ostadan Dec at para 10
2 The cask and the concrete pad may develop cold bonding Ostadan Dec para 10 Thecold bonding causes a contact condition between the cask and the pad that is notcovered by the coefficient of friction 08 Ostadan Dec at para 10
3 The cold bonding may break during seismic shaking in a nonuniform pattern causinga nonuniform contact condition between the cask and the pad Ostadan Dec at para 10The coefficient of friction would not remain constant
4 The State disputes PFS Material Fact No 11 in that the two coefficients of friction02 and 08 do not effectively bracket any variation in the coefficient of friction overthe surface of the pad Ostadan Dec at IT 7 8 9 11
5 The coefficient of friction between the cask and the concrete pad is not uniformacross the surface of the cask Ostadan Dec at T 9
6 The concrete pad will not behave as a rigid surface under either static or dynamicloading Ostadan Dec at para 8
7 Due to the flexible nature of the pad the coefficient of friction will be dependentupon frictional forces Ostadan Dec at para 8
8 The contact surface between the bottom of the cask and the top of the foundation padwill not remain intact during cask loading or seismic movement Ostadan Dec at para 8
UNITED STATES OF AMERICA NUCLEAR REGULA TORY COMMISSION
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
) In the Matter of ) Docket No 72-22-ISFSI
) PRNATE FUEL STORAGE LLC ) ASLBP No 97-732-02-ISFSI (Independent Spent Fuel )
Storage Installation) ) January 21 2000
DECLARATION OF FARHANG OSTADAN PH D
I FARHANG OSTADAN hereby declare under penalty ofperjury and pursuant to 28
USC sect 1746 that
1 I hold a PhD in civil engineering from the University of
California at Berkeley My curriculum vitae listing my qualifications experience
training and publications has already been filed in this proceeding See Exhibit No2 of
the States Motion to Compel Applicant to Respond to States Fifth Set of Discovery
Requests dated December 20 1999
2 I have fifteen years experience in dynamic analysis and seismic
safety evaluation of above and underground structures and subsurface materials I coshy
developed and implemented SASSI a system for seismic soil-structure interaction
analysis currently in use by the industry worldwide I also developed a method for
liquefaction hazard analysis currently in use for critical facilities in the United States
3 I have participated in seismic studies and review of numerous
nuclear structures including Diablo Canyon Nuclear Station and the NRCEPRllarge
scale seismic experiment in Lotung Taiwan I have published numerous papers in the
area of soil structure interaction and seismic design
4 I have read the materials filed by PFS in support of its Motion for
Summary Disposition of Contention GG including the Safety Analysis Report for the
TranStor Storage Cask System rev B the TranS tor Storage Cask Seismic Stability
Analysis for PFS Site July 24 1997 (Private Utility Fuel Storage Project Cask Seismic
Tipover Analysis prepared for Sierra Nuclear Corporation by Advent Engineering
Services Inc (hereinafter Advent Report)) the PFSF Site Specific Cask Stability
Analysis for the TranStor Storage Cask September 23 1999 and the TranStor
Dynamic Response to 2000 Year Return Seismic Event Holtec Report No HI-99229S
I am familiar with the circumstances and materials in this case as they relate to
Contention GG including PFSs Safety Analysis Report I am also familiar with and have
reviewed the documents that PFS has provided to the State ofUtah concerning Utah
Contention GG PFSs responses to Discovery Requests submitted by the State and
PFSs responses to the NRC Staffs Requests for Additional Information
5 The Applicant has performed a series of simple nonlinear time
history analyses in which the interaction between the cask and the foundation pad is
modeled by frictional elements The coefficient offuction was changed in successive
analyses from 020 to 080 Soler Dec Sum Disp at ~ 9
6 Dr Alan Soler states that the coefficient of friction is a property
2
associated with a contact point between two surfaces and the value of the coefficient is
dependent on the characteristics of the two materials at the interface contact point Soler
Dec Sum Disp at ~ 7 In a declaration supporting the Applicants Response to State of
Utahs Motion to Compel Applicant to Respond to States Fifth Set of Discovery
Requests Dr Solar claims that the coefficient of friction is independent of the friction
forces Solar Dec Resp Mo Compel at ~ 10 However the coefficient of friction is
only independent of friction forces under certain circumstances
7 In justifying that the coefficient of friction is independent of
friction forces Dr Soler must assume that the contact surface between the bottom of the
cask and top of the foundation will remain intact after loading the casks on the pad and
during the seismic excitation which effectively implies that the concrete pad is rigid under
both static and dynamic loading This assumption led the Applicant to the simplifying
assumption for the dynamic analysis of the cask by using simple frictional elements at the
contact points
8 However using the Applicants parameters including the
coefficient ofthe subgrade reaction of275 kipsft3 (SAR Rev 8 at 26-35) and the pad
dimensions (SAR Rev 8 at 26-87) and the relationship described in Foundation
Analysis and Design Fourth edition Joseph Bowels McGraw Hill Company 1988
Section 97 hereto attached as Exhibit A to distinguish a flexible versus a rigid mat I
have calculated that the pad will not be rigid and in fact will deform when subjected to
cask loading Thus Dr Solers assumption that the cask pad is rigid is incorrect
3
Moreover because the pad is flexible the coefficient of friction is dependent on friction
forces and will be affected at the contact points between the cask and the pad
9 Under dynamic loading the dynamic properties of a flexible pad
are different from those of a rigid pad I The flexible behavior of the foundation pad will
amplify under the inertia of the casks on the pad Thus the coefficient of friction will not
be constant across the pad and the Applicants analysis of uniform coefficient of friction
will not bound the actual behavior of the casks and the pad
10 It is also possible that the casks on the pad could develop a cold
bonding over time The cold bonding causes a contact condition between the cask and
the pad that is not covered by the highest coefficient of friction used by the Applicant
Additionally the effect of the cold bonding is not necessarily the same as the hinge
condition that the Applicant assumed in the previous Advent analysis 2 The bonding may
break during seismic shaking in a nonuniform pattern depending on the contact stresses
causing a nonuniform contact condition between the cask and the pad
11 Within the context of Contention GG and the modeling technique
used by the Applicant and considering the realistic and flexible behavior of the pad under
1 An excellent comparison of the dynamic properties of rigid versus flexible foundation is presented by Iguchi and Luco in Dynamic response ofFlexible Rectangular Foundations on an Elastic Halfspace Journal of Earthquake Engineering and Structural dynamics 1981 Vol 9
2 The Advent Report assumed that the cask was analytically pinned at one edge and did not consider the coefficients of friction Soler Dec Sum Disp at ~ 4
4
P0011001
BOI j56C292 p C06
ootil the statIc find dy11amic loading il is my opinion (hili the 1joltec 2000 analysis relied
llpon by lhe Aptllicant till falls to considcrvarilltiOli of coelilcicm Qf friction over the
surfllce ofthc pad and the shift from static case to kinetic cnsc
12 This Declaration hils been prepared in 5UPPO( of the State of
Utahs RLlsponse to Applicants M~llion for Summary Disposition ()(Contcntion Utuh
GG and Lhe Slates nccomp~nying Statement of Msnelial ract~ and is trile and correct to
the best M my knowledge nnd beief
DATED thi~ January 21 ~woo
ATTACHMENT A
LlLJI
IlUUJ 110 t1l70
FOUNDA11Ul~ UVJVVIJ
ANALYSIS Al1J)
DESIGN Fourth Edition
Joseph E Bowles PE SE Ctmsulril1 ilIgilllerStJjrwtlre C(msullam
~1If1IrIfill~J c~mlllt(r SI(flllrt Poritl lIIimljs
McGraw-lUll Publishina Company New York St Louu SAIl Frlllciseo lullkllllld HOlloW Canebullbull
HlIMbllrs Utbon Loodon MdrW Mtldco Milan MQflJnzl New Delhi OItlaho1na Ciqo Pan Son 111amp11
sro Plo SlngporI Syc1llY Tokyo TorqllQ
I
V 1 _ v
410 FouNDATION ANALVSlS AND DI5KlN
97 CLASSICAL SOLllTION OF BEAM ON ELASTIC FOlJNDAnON
When tlexur1 rigidity oCthe [aotin iii taken into accounl a solution is used that is based on some fonn of a heam on an elEl~tic (oundaLlon This may be of the classical Winkler solution of about 1861 in which the founchulon is considered as a bed of sprins (Winkler round ation) or a nnllgteement procedure of the nex section
The classical solutions being of closed ronn are not as ~ncra in application as the finite-clement merhod The basic differential equal ion is (see Fie 9-10)
pound1 dXlJy q - k~y (9-1l)
JAN -20 OO(THU) 1018
SPJ(IAL morlNOS owp BIlAS ON f)Imc ~(lIlNIgtIlTIONS 411
TABLE)2 Cloted-form Bolldons of infinite beam on Iseric fOlndlltiQn (Fig 9middot1011)
-VI M=TBu
Q -VIC
CflrJCllnrnltuli 101141 QI tilnln Moment III CDnllllf
MJl J -k- Bu dcllcclion
P M =rrcbullbull
-I -MeQ=-1gt Q= -2- A shear
Z
The A B C IiLPd D COtlfficienLS are
A =- o~) + silll)
BJgtt c-lmiddot ~in AX
Cl~ - middot(cosx - sin ltx)
1J1~ -u COampx
where k kB In solvin the equations a variable is inLroduced
bull 4 (iii )Iii -Jill or
TabJe 9middot2 Sives the closedmiddotfonn solution of t e basic differential equations for scveralloadingll shown in Fig 9-10 ulilizing the Winkler concept It is convCJliell~ to express the trigonometric portion of the solutions sepannely as in tbe bottom of Table 9middot2
He~enyi (1946) developed equations for a load at any point along a beam (see Fig 9middot10b) mea~ured from the len end as rallows
JAN -20 00 (THU) 1018 BEl TEL415 768 4898 p 004005
412 FOlNDAT10N ANALYSIS NI) OESION
k = kiP Hncludes cffic or BJ
-----) -----0 cUM [b) Finite length beam cn elUlic
(oundation ---
--~----~gt~~-r--IJ~lt~--~~~M I ~~
Moment curve
Ii ---shy ~ Q ---~~
~ Shear curve
ta) Infillitc Icnlh beam an an elude rOllndatlan
FIGUDE 1)10 Beam on eillstic roundaticm
Y k~ (sinh ~l_ sjJl2 AL) 2 cosh AX cosu (sinh U cos la cosh)b
-ilin L cosh )(J cos lb) + (cosh It-X sin lx
+ sinh 1x cos tx) [sinh U (sin)a cosh 1b - cos ttl sinh lb)
+~j )L (sinh lQ cos)b - cosh ia sin Ah)J) (9middot12)
M a t ( hl ~ l AL) 2 sin AX sin h (sinh tL cos ~ cosb lb _ SIn I - SUI
- Sill U cosh AU WS ~iJ - l~osh 1( sinlx - sillh lx cos AX)
x [sinh)L (sin ta cosb 1b - cos )a sinh )b)
+sill )L sinh l cos ib - coshit sin ib)J (9-13)
-- TEL415 768 4898 JAN -20 OOTHUI 1018 BEl bull __ ~ bullbull nM~1gt UN ElAT1C rOU~tgtAIr)NS 411
x (sinh L cos AQ cosh Jb - sin iL cosh AQ CQS )h)
+ sinh Ax sin i( [sinh L (sin la cosh b shy cos 1Q sinh lb)
+ sin )L (liinh )a etlS h shy cosh AQ sin )b)]
The equation far the slope eof the beam at any point is not pre$ented is of little value in the design of a footing The value of x to use in the equa from the end o the beam to the point ror which the deOection moment or desired If x is less than the distance use the equations lS given and meaSUf x from C Ifx is largdf than a replace a with b in the equations and measure x from D (Fig 9middottOb) These equations may be rewritten as
Y=~A M=S and QPCk ~A
whllre the coeffioients A B and C are the values or the hyperbolic and trigonometric remainder of Eqs (9-12) to (9middot14)
It has been proposed that one could u~e U previously defined to determine if a foundation should be analyzed 011 the basis of the conventional rigid procedure Or as a beam on an elastic foundation
Rigi members (bending not influenced much by k)
(bending bcavity localized)
e 8l1tbor has found the above criteria 0 1 e app leation bocause of the infiuence or number of loads and their locations on the member
The classical solution presented here has several distinct disadviulluges over the finj[~middotelement solution presented i~ the next section such as
I Assumes weipoundhtless beam (but weight wUl be a factor when footing tends to stlparate from the soil)
2 Difficult to remove soil effect when footing tends to separate [rom soil 3 Difficult [0 account for boundary conditions orknown rotation or deflection at
seleCted points 4 Difficult to apply multiple types or loads to a foolina S Difficult to chanse footins properties of I D and B 6 Difficult to allow for change in subgrade reaclion along fOOling
Although tbe disltdvaruages are substantial iome engineeri prefer the classical beatll-onelaslic-foundation approacb over discrete element analyses Rarely the classical approach may be a better model than a discrete elemetn analysis so it is worthwhile to have access to ilii5 method of solution
P 005005
Analysis will not accurately predict the stability of the casks under dynamic conditions
because the coefficient of friction will depend on frictional forces See id The high and
low coefficients of friction employed in the Revised Analysis will not bound the actual
frictional behavior because the Revised Analysis is based on the assumption that
frictional forces will not affect the coefficient of friction See id para 9
Second the Revised Analysis did not take into account the effects of cold
bonding See id para 10 This condition between the cask and the pad is not covered by the
highest coefficient of friction (08) See id see also Revised Analysis If a cold bond
were broken during seismic activity it could cause the contact points between the casks
and pad to be nonuniform See Ostadan Dec 1 10 Since the Revised Analysis only
considered simple friction elements see id para 7 the actual frictional forces may fall
outside the high bound of the coefficients of friction used in the Revised Analysis In
other words if cold bonding were to occur the coefficient of friction would be higher
than 08 (the highest value analyzed in the Revised Analysis) See Ostadan Dec para 10
While the Revised Analysis attempts to account for coefficients of friction over
the surface of the pad the Revised Analysis fails to account for the actual variations in
coefficients of friction Moreover the use of 08 does not bound the highest coefficient
of friction such that may occur during cold bonding Therefore the Revised Analysis
does not render Utah Contention GG moot
II PFS Is Not Entitled to Summary Disposition Because There Are Genuine Issuesof Material Facts
A movant is only entitled to summary disposition when there are no genuine
5
issues of material facts See Advanced Medical Systems Inc (One Factory Row
Geneva Ohio 44041) CLI-93-22 38 NRC 98 102 (1993) PFS claims that there are no
genuine issues of material fact See PFS Motion at 5 However Dr Ostadans
Declaration raises several issues regarding the accuracy of the Revised Analysis thereby
rendering summary disposition inapplicable
Dr Ostadan after reviewing the Revised Analysis has concluded that the
Analysis is incorrect and fails to consider the actual coefficients of friction that would
occur during seismic activity See Ostadan Dec mpara 7-10 Specifically there is a genuine
issue as to whether the pad will remain rigid under cask loading See id m 7-8
Moreover there is a dispute as to whether simple frictional elements applied at
coefficients of friction of 02 and 08 bound the actual behavior of the casks under
dynamic loading Compare PFS Motion at 6-7 with Ostadans Dec mpara 9-10 Apparently
Dr Soler relies on the assumption that the coefficient of friction is independent of
frictional forces See Soler Declaration in Support of Applicants December 27 1999
Response to Utahs Motion to Compel Applicant to Respond to States Fifth Set of
Discovery Requests para 10 The State disputes the fact that the coefficient of friction is
independent of frictional force and dynamic loading See Ostadans Dec para 8 Since the
coefficient of friction is dependent on dynamic forces under the circumstances it is
material to the issue of whether the Revised Analysis considers the variability of
coefficients of friction over the pad
All of these disputes directly relate to the accuracy of the Revised Analysis and
the variability of the coefficient of friction over the pad These factual disputes taken in
6
the light most favorable to the State entitle the State to go forward with Contention GG
Therefore the PFS Motion must be denied
DATED this 21 st day of January 2000
Respec submitted
Denise Chancellor Assistant Attorney GeneralFred G Nelson Assistant Attorney GeneralConnie Nakahara Special Assistant Attorney GeneralDiane Curran Special Assistant Attorney GeneralLaura Lockhart Assistant Attorney GeneralAttorneys for State of Utah Utah Attorney Generals Office160 East 300 South 5th Floor PO Box 140873Salt Lake City UT 84114-0873Telephone (801) 366-0286 Fax (801) 366-0292
7
CERTIFICATE OF SERVICE -1 -i 1 - - -- -
J 1i G 7 - I t L i__ _ tJI i I F4
I hereby certify that a copy of STATE OF UTAHS RESPONSE TO THEgt00 JN 27 7 53
APPLICANTS MOTION FOR SUMMARY DISPOSITION OF UTAH CONTENTION
GG - FAILURE TO DEMONSTRATE CASK-PAD STABILITY DURING SEISMIC
EVENT FOR TRANSTOR CASKS was served on the persons listed below by electronic
mail (unless otherwise noted) with conforming copies by United States mail first class
this 21 st day of January 2000
Emile L Julian Assistant forRulemakings and Adjudications
Rulemaking amp Adjudication StaffSecretary of the CommissionU S Nuclear Regulatory CommissionWashington DC 20555E-mail hearingdocket~nrcgov(original and two copies)
G Paul Bollwerk HI ChairmanAdministrative JudgeAtomic Safety and Licensing BoardU S Nuclear Regulatory CommissionWashington DC 20555E-Mail gpb~nrcgov
Dr Jerry R KlineAdministrative JudgeAtomic Safety and Licensing BoardU S Nuclear Regulatory CommissionWashington DC 20555E-Mail jrk2nrcgovE-Mail kjerrygerolscom
Dr Peter S LamAdministrative JudgeAtomic Safety and Licensing BoardU S Nuclear Regulatory CommissionWashington DC 20555E-Mail psl~nrcgov
Sherwin E Turk EsqCatherine L Marco EsqOffice of the General Counsel
Mail Stop O-15-B-18US Nuclear Regulatory CommissionWashington DC 20555E-Mail setgnrcgovE-Mail clm~nrcgov
Jay E Silberg EsqErnest L Blake Jr EsqPaul A Gaukler EsqShaw Pittman Potts amp Trowbridge2300 N Street N WWashington DC 20037-8007E-Mail JaySilberg~shawpittmancomE-Mail ernestblakegshawpittmancomE-Mail paulgaukler~shawpittmancom
8
John Paul Kennedy Sr Esq1385 Yale AvenueSalt Lake City Utah 84105E-Mail john~kennedysorg
Joro Walker EsqLand and Water Fund of the Rockies2056 East 3300 South Street Suite ISalt Lake City Utah 84109E-Mail joro61inconnectcom
Danny Quintana EsqDanny Quintana amp Associates PC68 South Main Street Suite 600Salt Lake City Utah 84101E-Mail quintana~xmissioncom
James M CutchinAtomic Safety and Licensing Board PanelUS Nuclear Regulatory CommissionWashington DC 20555-0001E-Mail jmc3nrcgov(electronic copy only)
Office of the Commission AppellateAdjudication
Mail Stop 014-G-15U S Nuclear Regulatory CommissionWashington DC 20555
Assistant Attorney GeneralState of Utah
9
UNITED STATES OF AMERICANUCLEAR REGULATORY COMMISSION
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)_In the Matter of ) Docket No 72-22-ISFSI
)PRIVATE FUEL STORAGE LLC ) ASLBP No 97-732-02-ISFSI(Independent Spent Fuel )
Storage Installation) ) January 21 2000
STATE OF UTAHS STATEMENT OF DISPUTEDAND RELEVANT MATERIAL FACTS FOR UTAH CONTENTION GG
1 The State disputes PFS Material Fact No 10 in that 08 does not bound the highestcoefficient of friction expected to occur Ostadan Dec at para 10
2 The cask and the concrete pad may develop cold bonding Ostadan Dec para 10 Thecold bonding causes a contact condition between the cask and the pad that is notcovered by the coefficient of friction 08 Ostadan Dec at para 10
3 The cold bonding may break during seismic shaking in a nonuniform pattern causinga nonuniform contact condition between the cask and the pad Ostadan Dec at para 10The coefficient of friction would not remain constant
4 The State disputes PFS Material Fact No 11 in that the two coefficients of friction02 and 08 do not effectively bracket any variation in the coefficient of friction overthe surface of the pad Ostadan Dec at IT 7 8 9 11
5 The coefficient of friction between the cask and the concrete pad is not uniformacross the surface of the cask Ostadan Dec at T 9
6 The concrete pad will not behave as a rigid surface under either static or dynamicloading Ostadan Dec at para 8
7 Due to the flexible nature of the pad the coefficient of friction will be dependentupon frictional forces Ostadan Dec at para 8
8 The contact surface between the bottom of the cask and the top of the foundation padwill not remain intact during cask loading or seismic movement Ostadan Dec at para 8
UNITED STATES OF AMERICA NUCLEAR REGULA TORY COMMISSION
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
) In the Matter of ) Docket No 72-22-ISFSI
) PRNATE FUEL STORAGE LLC ) ASLBP No 97-732-02-ISFSI (Independent Spent Fuel )
Storage Installation) ) January 21 2000
DECLARATION OF FARHANG OSTADAN PH D
I FARHANG OSTADAN hereby declare under penalty ofperjury and pursuant to 28
USC sect 1746 that
1 I hold a PhD in civil engineering from the University of
California at Berkeley My curriculum vitae listing my qualifications experience
training and publications has already been filed in this proceeding See Exhibit No2 of
the States Motion to Compel Applicant to Respond to States Fifth Set of Discovery
Requests dated December 20 1999
2 I have fifteen years experience in dynamic analysis and seismic
safety evaluation of above and underground structures and subsurface materials I coshy
developed and implemented SASSI a system for seismic soil-structure interaction
analysis currently in use by the industry worldwide I also developed a method for
liquefaction hazard analysis currently in use for critical facilities in the United States
3 I have participated in seismic studies and review of numerous
nuclear structures including Diablo Canyon Nuclear Station and the NRCEPRllarge
scale seismic experiment in Lotung Taiwan I have published numerous papers in the
area of soil structure interaction and seismic design
4 I have read the materials filed by PFS in support of its Motion for
Summary Disposition of Contention GG including the Safety Analysis Report for the
TranStor Storage Cask System rev B the TranS tor Storage Cask Seismic Stability
Analysis for PFS Site July 24 1997 (Private Utility Fuel Storage Project Cask Seismic
Tipover Analysis prepared for Sierra Nuclear Corporation by Advent Engineering
Services Inc (hereinafter Advent Report)) the PFSF Site Specific Cask Stability
Analysis for the TranStor Storage Cask September 23 1999 and the TranStor
Dynamic Response to 2000 Year Return Seismic Event Holtec Report No HI-99229S
I am familiar with the circumstances and materials in this case as they relate to
Contention GG including PFSs Safety Analysis Report I am also familiar with and have
reviewed the documents that PFS has provided to the State ofUtah concerning Utah
Contention GG PFSs responses to Discovery Requests submitted by the State and
PFSs responses to the NRC Staffs Requests for Additional Information
5 The Applicant has performed a series of simple nonlinear time
history analyses in which the interaction between the cask and the foundation pad is
modeled by frictional elements The coefficient offuction was changed in successive
analyses from 020 to 080 Soler Dec Sum Disp at ~ 9
6 Dr Alan Soler states that the coefficient of friction is a property
2
associated with a contact point between two surfaces and the value of the coefficient is
dependent on the characteristics of the two materials at the interface contact point Soler
Dec Sum Disp at ~ 7 In a declaration supporting the Applicants Response to State of
Utahs Motion to Compel Applicant to Respond to States Fifth Set of Discovery
Requests Dr Solar claims that the coefficient of friction is independent of the friction
forces Solar Dec Resp Mo Compel at ~ 10 However the coefficient of friction is
only independent of friction forces under certain circumstances
7 In justifying that the coefficient of friction is independent of
friction forces Dr Soler must assume that the contact surface between the bottom of the
cask and top of the foundation will remain intact after loading the casks on the pad and
during the seismic excitation which effectively implies that the concrete pad is rigid under
both static and dynamic loading This assumption led the Applicant to the simplifying
assumption for the dynamic analysis of the cask by using simple frictional elements at the
contact points
8 However using the Applicants parameters including the
coefficient ofthe subgrade reaction of275 kipsft3 (SAR Rev 8 at 26-35) and the pad
dimensions (SAR Rev 8 at 26-87) and the relationship described in Foundation
Analysis and Design Fourth edition Joseph Bowels McGraw Hill Company 1988
Section 97 hereto attached as Exhibit A to distinguish a flexible versus a rigid mat I
have calculated that the pad will not be rigid and in fact will deform when subjected to
cask loading Thus Dr Solers assumption that the cask pad is rigid is incorrect
3
Moreover because the pad is flexible the coefficient of friction is dependent on friction
forces and will be affected at the contact points between the cask and the pad
9 Under dynamic loading the dynamic properties of a flexible pad
are different from those of a rigid pad I The flexible behavior of the foundation pad will
amplify under the inertia of the casks on the pad Thus the coefficient of friction will not
be constant across the pad and the Applicants analysis of uniform coefficient of friction
will not bound the actual behavior of the casks and the pad
10 It is also possible that the casks on the pad could develop a cold
bonding over time The cold bonding causes a contact condition between the cask and
the pad that is not covered by the highest coefficient of friction used by the Applicant
Additionally the effect of the cold bonding is not necessarily the same as the hinge
condition that the Applicant assumed in the previous Advent analysis 2 The bonding may
break during seismic shaking in a nonuniform pattern depending on the contact stresses
causing a nonuniform contact condition between the cask and the pad
11 Within the context of Contention GG and the modeling technique
used by the Applicant and considering the realistic and flexible behavior of the pad under
1 An excellent comparison of the dynamic properties of rigid versus flexible foundation is presented by Iguchi and Luco in Dynamic response ofFlexible Rectangular Foundations on an Elastic Halfspace Journal of Earthquake Engineering and Structural dynamics 1981 Vol 9
2 The Advent Report assumed that the cask was analytically pinned at one edge and did not consider the coefficients of friction Soler Dec Sum Disp at ~ 4
4
P0011001
BOI j56C292 p C06
ootil the statIc find dy11amic loading il is my opinion (hili the 1joltec 2000 analysis relied
llpon by lhe Aptllicant till falls to considcrvarilltiOli of coelilcicm Qf friction over the
surfllce ofthc pad and the shift from static case to kinetic cnsc
12 This Declaration hils been prepared in 5UPPO( of the State of
Utahs RLlsponse to Applicants M~llion for Summary Disposition ()(Contcntion Utuh
GG and Lhe Slates nccomp~nying Statement of Msnelial ract~ and is trile and correct to
the best M my knowledge nnd beief
DATED thi~ January 21 ~woo
ATTACHMENT A
LlLJI
IlUUJ 110 t1l70
FOUNDA11Ul~ UVJVVIJ
ANALYSIS Al1J)
DESIGN Fourth Edition
Joseph E Bowles PE SE Ctmsulril1 ilIgilllerStJjrwtlre C(msullam
~1If1IrIfill~J c~mlllt(r SI(flllrt Poritl lIIimljs
McGraw-lUll Publishina Company New York St Louu SAIl Frlllciseo lullkllllld HOlloW Canebullbull
HlIMbllrs Utbon Loodon MdrW Mtldco Milan MQflJnzl New Delhi OItlaho1na Ciqo Pan Son 111amp11
sro Plo SlngporI Syc1llY Tokyo TorqllQ
I
V 1 _ v
410 FouNDATION ANALVSlS AND DI5KlN
97 CLASSICAL SOLllTION OF BEAM ON ELASTIC FOlJNDAnON
When tlexur1 rigidity oCthe [aotin iii taken into accounl a solution is used that is based on some fonn of a heam on an elEl~tic (oundaLlon This may be of the classical Winkler solution of about 1861 in which the founchulon is considered as a bed of sprins (Winkler round ation) or a nnllgteement procedure of the nex section
The classical solutions being of closed ronn are not as ~ncra in application as the finite-clement merhod The basic differential equal ion is (see Fie 9-10)
pound1 dXlJy q - k~y (9-1l)
JAN -20 OO(THU) 1018
SPJ(IAL morlNOS owp BIlAS ON f)Imc ~(lIlNIgtIlTIONS 411
TABLE)2 Cloted-form Bolldons of infinite beam on Iseric fOlndlltiQn (Fig 9middot1011)
-VI M=TBu
Q -VIC
CflrJCllnrnltuli 101141 QI tilnln Moment III CDnllllf
MJl J -k- Bu dcllcclion
P M =rrcbullbull
-I -MeQ=-1gt Q= -2- A shear
Z
The A B C IiLPd D COtlfficienLS are
A =- o~) + silll)
BJgtt c-lmiddot ~in AX
Cl~ - middot(cosx - sin ltx)
1J1~ -u COampx
where k kB In solvin the equations a variable is inLroduced
bull 4 (iii )Iii -Jill or
TabJe 9middot2 Sives the closedmiddotfonn solution of t e basic differential equations for scveralloadingll shown in Fig 9-10 ulilizing the Winkler concept It is convCJliell~ to express the trigonometric portion of the solutions sepannely as in tbe bottom of Table 9middot2
He~enyi (1946) developed equations for a load at any point along a beam (see Fig 9middot10b) mea~ured from the len end as rallows
JAN -20 00 (THU) 1018 BEl TEL415 768 4898 p 004005
412 FOlNDAT10N ANALYSIS NI) OESION
k = kiP Hncludes cffic or BJ
-----) -----0 cUM [b) Finite length beam cn elUlic
(oundation ---
--~----~gt~~-r--IJ~lt~--~~~M I ~~
Moment curve
Ii ---shy ~ Q ---~~
~ Shear curve
ta) Infillitc Icnlh beam an an elude rOllndatlan
FIGUDE 1)10 Beam on eillstic roundaticm
Y k~ (sinh ~l_ sjJl2 AL) 2 cosh AX cosu (sinh U cos la cosh)b
-ilin L cosh )(J cos lb) + (cosh It-X sin lx
+ sinh 1x cos tx) [sinh U (sin)a cosh 1b - cos ttl sinh lb)
+~j )L (sinh lQ cos)b - cosh ia sin Ah)J) (9middot12)
M a t ( hl ~ l AL) 2 sin AX sin h (sinh tL cos ~ cosb lb _ SIn I - SUI
- Sill U cosh AU WS ~iJ - l~osh 1( sinlx - sillh lx cos AX)
x [sinh)L (sin ta cosb 1b - cos )a sinh )b)
+sill )L sinh l cos ib - coshit sin ib)J (9-13)
-- TEL415 768 4898 JAN -20 OOTHUI 1018 BEl bull __ ~ bullbull nM~1gt UN ElAT1C rOU~tgtAIr)NS 411
x (sinh L cos AQ cosh Jb - sin iL cosh AQ CQS )h)
+ sinh Ax sin i( [sinh L (sin la cosh b shy cos 1Q sinh lb)
+ sin )L (liinh )a etlS h shy cosh AQ sin )b)]
The equation far the slope eof the beam at any point is not pre$ented is of little value in the design of a footing The value of x to use in the equa from the end o the beam to the point ror which the deOection moment or desired If x is less than the distance use the equations lS given and meaSUf x from C Ifx is largdf than a replace a with b in the equations and measure x from D (Fig 9middottOb) These equations may be rewritten as
Y=~A M=S and QPCk ~A
whllre the coeffioients A B and C are the values or the hyperbolic and trigonometric remainder of Eqs (9-12) to (9middot14)
It has been proposed that one could u~e U previously defined to determine if a foundation should be analyzed 011 the basis of the conventional rigid procedure Or as a beam on an elastic foundation
Rigi members (bending not influenced much by k)
(bending bcavity localized)
e 8l1tbor has found the above criteria 0 1 e app leation bocause of the infiuence or number of loads and their locations on the member
The classical solution presented here has several distinct disadviulluges over the finj[~middotelement solution presented i~ the next section such as
I Assumes weipoundhtless beam (but weight wUl be a factor when footing tends to stlparate from the soil)
2 Difficult to remove soil effect when footing tends to separate [rom soil 3 Difficult [0 account for boundary conditions orknown rotation or deflection at
seleCted points 4 Difficult to apply multiple types or loads to a foolina S Difficult to chanse footins properties of I D and B 6 Difficult to allow for change in subgrade reaclion along fOOling
Although tbe disltdvaruages are substantial iome engineeri prefer the classical beatll-onelaslic-foundation approacb over discrete element analyses Rarely the classical approach may be a better model than a discrete elemetn analysis so it is worthwhile to have access to ilii5 method of solution
P 005005
issues of material facts See Advanced Medical Systems Inc (One Factory Row
Geneva Ohio 44041) CLI-93-22 38 NRC 98 102 (1993) PFS claims that there are no
genuine issues of material fact See PFS Motion at 5 However Dr Ostadans
Declaration raises several issues regarding the accuracy of the Revised Analysis thereby
rendering summary disposition inapplicable
Dr Ostadan after reviewing the Revised Analysis has concluded that the
Analysis is incorrect and fails to consider the actual coefficients of friction that would
occur during seismic activity See Ostadan Dec mpara 7-10 Specifically there is a genuine
issue as to whether the pad will remain rigid under cask loading See id m 7-8
Moreover there is a dispute as to whether simple frictional elements applied at
coefficients of friction of 02 and 08 bound the actual behavior of the casks under
dynamic loading Compare PFS Motion at 6-7 with Ostadans Dec mpara 9-10 Apparently
Dr Soler relies on the assumption that the coefficient of friction is independent of
frictional forces See Soler Declaration in Support of Applicants December 27 1999
Response to Utahs Motion to Compel Applicant to Respond to States Fifth Set of
Discovery Requests para 10 The State disputes the fact that the coefficient of friction is
independent of frictional force and dynamic loading See Ostadans Dec para 8 Since the
coefficient of friction is dependent on dynamic forces under the circumstances it is
material to the issue of whether the Revised Analysis considers the variability of
coefficients of friction over the pad
All of these disputes directly relate to the accuracy of the Revised Analysis and
the variability of the coefficient of friction over the pad These factual disputes taken in
6
the light most favorable to the State entitle the State to go forward with Contention GG
Therefore the PFS Motion must be denied
DATED this 21 st day of January 2000
Respec submitted
Denise Chancellor Assistant Attorney GeneralFred G Nelson Assistant Attorney GeneralConnie Nakahara Special Assistant Attorney GeneralDiane Curran Special Assistant Attorney GeneralLaura Lockhart Assistant Attorney GeneralAttorneys for State of Utah Utah Attorney Generals Office160 East 300 South 5th Floor PO Box 140873Salt Lake City UT 84114-0873Telephone (801) 366-0286 Fax (801) 366-0292
7
CERTIFICATE OF SERVICE -1 -i 1 - - -- -
J 1i G 7 - I t L i__ _ tJI i I F4
I hereby certify that a copy of STATE OF UTAHS RESPONSE TO THEgt00 JN 27 7 53
APPLICANTS MOTION FOR SUMMARY DISPOSITION OF UTAH CONTENTION
GG - FAILURE TO DEMONSTRATE CASK-PAD STABILITY DURING SEISMIC
EVENT FOR TRANSTOR CASKS was served on the persons listed below by electronic
mail (unless otherwise noted) with conforming copies by United States mail first class
this 21 st day of January 2000
Emile L Julian Assistant forRulemakings and Adjudications
Rulemaking amp Adjudication StaffSecretary of the CommissionU S Nuclear Regulatory CommissionWashington DC 20555E-mail hearingdocket~nrcgov(original and two copies)
G Paul Bollwerk HI ChairmanAdministrative JudgeAtomic Safety and Licensing BoardU S Nuclear Regulatory CommissionWashington DC 20555E-Mail gpb~nrcgov
Dr Jerry R KlineAdministrative JudgeAtomic Safety and Licensing BoardU S Nuclear Regulatory CommissionWashington DC 20555E-Mail jrk2nrcgovE-Mail kjerrygerolscom
Dr Peter S LamAdministrative JudgeAtomic Safety and Licensing BoardU S Nuclear Regulatory CommissionWashington DC 20555E-Mail psl~nrcgov
Sherwin E Turk EsqCatherine L Marco EsqOffice of the General Counsel
Mail Stop O-15-B-18US Nuclear Regulatory CommissionWashington DC 20555E-Mail setgnrcgovE-Mail clm~nrcgov
Jay E Silberg EsqErnest L Blake Jr EsqPaul A Gaukler EsqShaw Pittman Potts amp Trowbridge2300 N Street N WWashington DC 20037-8007E-Mail JaySilberg~shawpittmancomE-Mail ernestblakegshawpittmancomE-Mail paulgaukler~shawpittmancom
8
John Paul Kennedy Sr Esq1385 Yale AvenueSalt Lake City Utah 84105E-Mail john~kennedysorg
Joro Walker EsqLand and Water Fund of the Rockies2056 East 3300 South Street Suite ISalt Lake City Utah 84109E-Mail joro61inconnectcom
Danny Quintana EsqDanny Quintana amp Associates PC68 South Main Street Suite 600Salt Lake City Utah 84101E-Mail quintana~xmissioncom
James M CutchinAtomic Safety and Licensing Board PanelUS Nuclear Regulatory CommissionWashington DC 20555-0001E-Mail jmc3nrcgov(electronic copy only)
Office of the Commission AppellateAdjudication
Mail Stop 014-G-15U S Nuclear Regulatory CommissionWashington DC 20555
Assistant Attorney GeneralState of Utah
9
UNITED STATES OF AMERICANUCLEAR REGULATORY COMMISSION
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)_In the Matter of ) Docket No 72-22-ISFSI
)PRIVATE FUEL STORAGE LLC ) ASLBP No 97-732-02-ISFSI(Independent Spent Fuel )
Storage Installation) ) January 21 2000
STATE OF UTAHS STATEMENT OF DISPUTEDAND RELEVANT MATERIAL FACTS FOR UTAH CONTENTION GG
1 The State disputes PFS Material Fact No 10 in that 08 does not bound the highestcoefficient of friction expected to occur Ostadan Dec at para 10
2 The cask and the concrete pad may develop cold bonding Ostadan Dec para 10 Thecold bonding causes a contact condition between the cask and the pad that is notcovered by the coefficient of friction 08 Ostadan Dec at para 10
3 The cold bonding may break during seismic shaking in a nonuniform pattern causinga nonuniform contact condition between the cask and the pad Ostadan Dec at para 10The coefficient of friction would not remain constant
4 The State disputes PFS Material Fact No 11 in that the two coefficients of friction02 and 08 do not effectively bracket any variation in the coefficient of friction overthe surface of the pad Ostadan Dec at IT 7 8 9 11
5 The coefficient of friction between the cask and the concrete pad is not uniformacross the surface of the cask Ostadan Dec at T 9
6 The concrete pad will not behave as a rigid surface under either static or dynamicloading Ostadan Dec at para 8
7 Due to the flexible nature of the pad the coefficient of friction will be dependentupon frictional forces Ostadan Dec at para 8
8 The contact surface between the bottom of the cask and the top of the foundation padwill not remain intact during cask loading or seismic movement Ostadan Dec at para 8
UNITED STATES OF AMERICA NUCLEAR REGULA TORY COMMISSION
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
) In the Matter of ) Docket No 72-22-ISFSI
) PRNATE FUEL STORAGE LLC ) ASLBP No 97-732-02-ISFSI (Independent Spent Fuel )
Storage Installation) ) January 21 2000
DECLARATION OF FARHANG OSTADAN PH D
I FARHANG OSTADAN hereby declare under penalty ofperjury and pursuant to 28
USC sect 1746 that
1 I hold a PhD in civil engineering from the University of
California at Berkeley My curriculum vitae listing my qualifications experience
training and publications has already been filed in this proceeding See Exhibit No2 of
the States Motion to Compel Applicant to Respond to States Fifth Set of Discovery
Requests dated December 20 1999
2 I have fifteen years experience in dynamic analysis and seismic
safety evaluation of above and underground structures and subsurface materials I coshy
developed and implemented SASSI a system for seismic soil-structure interaction
analysis currently in use by the industry worldwide I also developed a method for
liquefaction hazard analysis currently in use for critical facilities in the United States
3 I have participated in seismic studies and review of numerous
nuclear structures including Diablo Canyon Nuclear Station and the NRCEPRllarge
scale seismic experiment in Lotung Taiwan I have published numerous papers in the
area of soil structure interaction and seismic design
4 I have read the materials filed by PFS in support of its Motion for
Summary Disposition of Contention GG including the Safety Analysis Report for the
TranStor Storage Cask System rev B the TranS tor Storage Cask Seismic Stability
Analysis for PFS Site July 24 1997 (Private Utility Fuel Storage Project Cask Seismic
Tipover Analysis prepared for Sierra Nuclear Corporation by Advent Engineering
Services Inc (hereinafter Advent Report)) the PFSF Site Specific Cask Stability
Analysis for the TranStor Storage Cask September 23 1999 and the TranStor
Dynamic Response to 2000 Year Return Seismic Event Holtec Report No HI-99229S
I am familiar with the circumstances and materials in this case as they relate to
Contention GG including PFSs Safety Analysis Report I am also familiar with and have
reviewed the documents that PFS has provided to the State ofUtah concerning Utah
Contention GG PFSs responses to Discovery Requests submitted by the State and
PFSs responses to the NRC Staffs Requests for Additional Information
5 The Applicant has performed a series of simple nonlinear time
history analyses in which the interaction between the cask and the foundation pad is
modeled by frictional elements The coefficient offuction was changed in successive
analyses from 020 to 080 Soler Dec Sum Disp at ~ 9
6 Dr Alan Soler states that the coefficient of friction is a property
2
associated with a contact point between two surfaces and the value of the coefficient is
dependent on the characteristics of the two materials at the interface contact point Soler
Dec Sum Disp at ~ 7 In a declaration supporting the Applicants Response to State of
Utahs Motion to Compel Applicant to Respond to States Fifth Set of Discovery
Requests Dr Solar claims that the coefficient of friction is independent of the friction
forces Solar Dec Resp Mo Compel at ~ 10 However the coefficient of friction is
only independent of friction forces under certain circumstances
7 In justifying that the coefficient of friction is independent of
friction forces Dr Soler must assume that the contact surface between the bottom of the
cask and top of the foundation will remain intact after loading the casks on the pad and
during the seismic excitation which effectively implies that the concrete pad is rigid under
both static and dynamic loading This assumption led the Applicant to the simplifying
assumption for the dynamic analysis of the cask by using simple frictional elements at the
contact points
8 However using the Applicants parameters including the
coefficient ofthe subgrade reaction of275 kipsft3 (SAR Rev 8 at 26-35) and the pad
dimensions (SAR Rev 8 at 26-87) and the relationship described in Foundation
Analysis and Design Fourth edition Joseph Bowels McGraw Hill Company 1988
Section 97 hereto attached as Exhibit A to distinguish a flexible versus a rigid mat I
have calculated that the pad will not be rigid and in fact will deform when subjected to
cask loading Thus Dr Solers assumption that the cask pad is rigid is incorrect
3
Moreover because the pad is flexible the coefficient of friction is dependent on friction
forces and will be affected at the contact points between the cask and the pad
9 Under dynamic loading the dynamic properties of a flexible pad
are different from those of a rigid pad I The flexible behavior of the foundation pad will
amplify under the inertia of the casks on the pad Thus the coefficient of friction will not
be constant across the pad and the Applicants analysis of uniform coefficient of friction
will not bound the actual behavior of the casks and the pad
10 It is also possible that the casks on the pad could develop a cold
bonding over time The cold bonding causes a contact condition between the cask and
the pad that is not covered by the highest coefficient of friction used by the Applicant
Additionally the effect of the cold bonding is not necessarily the same as the hinge
condition that the Applicant assumed in the previous Advent analysis 2 The bonding may
break during seismic shaking in a nonuniform pattern depending on the contact stresses
causing a nonuniform contact condition between the cask and the pad
11 Within the context of Contention GG and the modeling technique
used by the Applicant and considering the realistic and flexible behavior of the pad under
1 An excellent comparison of the dynamic properties of rigid versus flexible foundation is presented by Iguchi and Luco in Dynamic response ofFlexible Rectangular Foundations on an Elastic Halfspace Journal of Earthquake Engineering and Structural dynamics 1981 Vol 9
2 The Advent Report assumed that the cask was analytically pinned at one edge and did not consider the coefficients of friction Soler Dec Sum Disp at ~ 4
4
P0011001
BOI j56C292 p C06
ootil the statIc find dy11amic loading il is my opinion (hili the 1joltec 2000 analysis relied
llpon by lhe Aptllicant till falls to considcrvarilltiOli of coelilcicm Qf friction over the
surfllce ofthc pad and the shift from static case to kinetic cnsc
12 This Declaration hils been prepared in 5UPPO( of the State of
Utahs RLlsponse to Applicants M~llion for Summary Disposition ()(Contcntion Utuh
GG and Lhe Slates nccomp~nying Statement of Msnelial ract~ and is trile and correct to
the best M my knowledge nnd beief
DATED thi~ January 21 ~woo
ATTACHMENT A
LlLJI
IlUUJ 110 t1l70
FOUNDA11Ul~ UVJVVIJ
ANALYSIS Al1J)
DESIGN Fourth Edition
Joseph E Bowles PE SE Ctmsulril1 ilIgilllerStJjrwtlre C(msullam
~1If1IrIfill~J c~mlllt(r SI(flllrt Poritl lIIimljs
McGraw-lUll Publishina Company New York St Louu SAIl Frlllciseo lullkllllld HOlloW Canebullbull
HlIMbllrs Utbon Loodon MdrW Mtldco Milan MQflJnzl New Delhi OItlaho1na Ciqo Pan Son 111amp11
sro Plo SlngporI Syc1llY Tokyo TorqllQ
I
V 1 _ v
410 FouNDATION ANALVSlS AND DI5KlN
97 CLASSICAL SOLllTION OF BEAM ON ELASTIC FOlJNDAnON
When tlexur1 rigidity oCthe [aotin iii taken into accounl a solution is used that is based on some fonn of a heam on an elEl~tic (oundaLlon This may be of the classical Winkler solution of about 1861 in which the founchulon is considered as a bed of sprins (Winkler round ation) or a nnllgteement procedure of the nex section
The classical solutions being of closed ronn are not as ~ncra in application as the finite-clement merhod The basic differential equal ion is (see Fie 9-10)
pound1 dXlJy q - k~y (9-1l)
JAN -20 OO(THU) 1018
SPJ(IAL morlNOS owp BIlAS ON f)Imc ~(lIlNIgtIlTIONS 411
TABLE)2 Cloted-form Bolldons of infinite beam on Iseric fOlndlltiQn (Fig 9middot1011)
-VI M=TBu
Q -VIC
CflrJCllnrnltuli 101141 QI tilnln Moment III CDnllllf
MJl J -k- Bu dcllcclion
P M =rrcbullbull
-I -MeQ=-1gt Q= -2- A shear
Z
The A B C IiLPd D COtlfficienLS are
A =- o~) + silll)
BJgtt c-lmiddot ~in AX
Cl~ - middot(cosx - sin ltx)
1J1~ -u COampx
where k kB In solvin the equations a variable is inLroduced
bull 4 (iii )Iii -Jill or
TabJe 9middot2 Sives the closedmiddotfonn solution of t e basic differential equations for scveralloadingll shown in Fig 9-10 ulilizing the Winkler concept It is convCJliell~ to express the trigonometric portion of the solutions sepannely as in tbe bottom of Table 9middot2
He~enyi (1946) developed equations for a load at any point along a beam (see Fig 9middot10b) mea~ured from the len end as rallows
JAN -20 00 (THU) 1018 BEl TEL415 768 4898 p 004005
412 FOlNDAT10N ANALYSIS NI) OESION
k = kiP Hncludes cffic or BJ
-----) -----0 cUM [b) Finite length beam cn elUlic
(oundation ---
--~----~gt~~-r--IJ~lt~--~~~M I ~~
Moment curve
Ii ---shy ~ Q ---~~
~ Shear curve
ta) Infillitc Icnlh beam an an elude rOllndatlan
FIGUDE 1)10 Beam on eillstic roundaticm
Y k~ (sinh ~l_ sjJl2 AL) 2 cosh AX cosu (sinh U cos la cosh)b
-ilin L cosh )(J cos lb) + (cosh It-X sin lx
+ sinh 1x cos tx) [sinh U (sin)a cosh 1b - cos ttl sinh lb)
+~j )L (sinh lQ cos)b - cosh ia sin Ah)J) (9middot12)
M a t ( hl ~ l AL) 2 sin AX sin h (sinh tL cos ~ cosb lb _ SIn I - SUI
- Sill U cosh AU WS ~iJ - l~osh 1( sinlx - sillh lx cos AX)
x [sinh)L (sin ta cosb 1b - cos )a sinh )b)
+sill )L sinh l cos ib - coshit sin ib)J (9-13)
-- TEL415 768 4898 JAN -20 OOTHUI 1018 BEl bull __ ~ bullbull nM~1gt UN ElAT1C rOU~tgtAIr)NS 411
x (sinh L cos AQ cosh Jb - sin iL cosh AQ CQS )h)
+ sinh Ax sin i( [sinh L (sin la cosh b shy cos 1Q sinh lb)
+ sin )L (liinh )a etlS h shy cosh AQ sin )b)]
The equation far the slope eof the beam at any point is not pre$ented is of little value in the design of a footing The value of x to use in the equa from the end o the beam to the point ror which the deOection moment or desired If x is less than the distance use the equations lS given and meaSUf x from C Ifx is largdf than a replace a with b in the equations and measure x from D (Fig 9middottOb) These equations may be rewritten as
Y=~A M=S and QPCk ~A
whllre the coeffioients A B and C are the values or the hyperbolic and trigonometric remainder of Eqs (9-12) to (9middot14)
It has been proposed that one could u~e U previously defined to determine if a foundation should be analyzed 011 the basis of the conventional rigid procedure Or as a beam on an elastic foundation
Rigi members (bending not influenced much by k)
(bending bcavity localized)
e 8l1tbor has found the above criteria 0 1 e app leation bocause of the infiuence or number of loads and their locations on the member
The classical solution presented here has several distinct disadviulluges over the finj[~middotelement solution presented i~ the next section such as
I Assumes weipoundhtless beam (but weight wUl be a factor when footing tends to stlparate from the soil)
2 Difficult to remove soil effect when footing tends to separate [rom soil 3 Difficult [0 account for boundary conditions orknown rotation or deflection at
seleCted points 4 Difficult to apply multiple types or loads to a foolina S Difficult to chanse footins properties of I D and B 6 Difficult to allow for change in subgrade reaclion along fOOling
Although tbe disltdvaruages are substantial iome engineeri prefer the classical beatll-onelaslic-foundation approacb over discrete element analyses Rarely the classical approach may be a better model than a discrete elemetn analysis so it is worthwhile to have access to ilii5 method of solution
P 005005
the light most favorable to the State entitle the State to go forward with Contention GG
Therefore the PFS Motion must be denied
DATED this 21 st day of January 2000
Respec submitted
Denise Chancellor Assistant Attorney GeneralFred G Nelson Assistant Attorney GeneralConnie Nakahara Special Assistant Attorney GeneralDiane Curran Special Assistant Attorney GeneralLaura Lockhart Assistant Attorney GeneralAttorneys for State of Utah Utah Attorney Generals Office160 East 300 South 5th Floor PO Box 140873Salt Lake City UT 84114-0873Telephone (801) 366-0286 Fax (801) 366-0292
7
CERTIFICATE OF SERVICE -1 -i 1 - - -- -
J 1i G 7 - I t L i__ _ tJI i I F4
I hereby certify that a copy of STATE OF UTAHS RESPONSE TO THEgt00 JN 27 7 53
APPLICANTS MOTION FOR SUMMARY DISPOSITION OF UTAH CONTENTION
GG - FAILURE TO DEMONSTRATE CASK-PAD STABILITY DURING SEISMIC
EVENT FOR TRANSTOR CASKS was served on the persons listed below by electronic
mail (unless otherwise noted) with conforming copies by United States mail first class
this 21 st day of January 2000
Emile L Julian Assistant forRulemakings and Adjudications
Rulemaking amp Adjudication StaffSecretary of the CommissionU S Nuclear Regulatory CommissionWashington DC 20555E-mail hearingdocket~nrcgov(original and two copies)
G Paul Bollwerk HI ChairmanAdministrative JudgeAtomic Safety and Licensing BoardU S Nuclear Regulatory CommissionWashington DC 20555E-Mail gpb~nrcgov
Dr Jerry R KlineAdministrative JudgeAtomic Safety and Licensing BoardU S Nuclear Regulatory CommissionWashington DC 20555E-Mail jrk2nrcgovE-Mail kjerrygerolscom
Dr Peter S LamAdministrative JudgeAtomic Safety and Licensing BoardU S Nuclear Regulatory CommissionWashington DC 20555E-Mail psl~nrcgov
Sherwin E Turk EsqCatherine L Marco EsqOffice of the General Counsel
Mail Stop O-15-B-18US Nuclear Regulatory CommissionWashington DC 20555E-Mail setgnrcgovE-Mail clm~nrcgov
Jay E Silberg EsqErnest L Blake Jr EsqPaul A Gaukler EsqShaw Pittman Potts amp Trowbridge2300 N Street N WWashington DC 20037-8007E-Mail JaySilberg~shawpittmancomE-Mail ernestblakegshawpittmancomE-Mail paulgaukler~shawpittmancom
8
John Paul Kennedy Sr Esq1385 Yale AvenueSalt Lake City Utah 84105E-Mail john~kennedysorg
Joro Walker EsqLand and Water Fund of the Rockies2056 East 3300 South Street Suite ISalt Lake City Utah 84109E-Mail joro61inconnectcom
Danny Quintana EsqDanny Quintana amp Associates PC68 South Main Street Suite 600Salt Lake City Utah 84101E-Mail quintana~xmissioncom
James M CutchinAtomic Safety and Licensing Board PanelUS Nuclear Regulatory CommissionWashington DC 20555-0001E-Mail jmc3nrcgov(electronic copy only)
Office of the Commission AppellateAdjudication
Mail Stop 014-G-15U S Nuclear Regulatory CommissionWashington DC 20555
Assistant Attorney GeneralState of Utah
9
UNITED STATES OF AMERICANUCLEAR REGULATORY COMMISSION
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)_In the Matter of ) Docket No 72-22-ISFSI
)PRIVATE FUEL STORAGE LLC ) ASLBP No 97-732-02-ISFSI(Independent Spent Fuel )
Storage Installation) ) January 21 2000
STATE OF UTAHS STATEMENT OF DISPUTEDAND RELEVANT MATERIAL FACTS FOR UTAH CONTENTION GG
1 The State disputes PFS Material Fact No 10 in that 08 does not bound the highestcoefficient of friction expected to occur Ostadan Dec at para 10
2 The cask and the concrete pad may develop cold bonding Ostadan Dec para 10 Thecold bonding causes a contact condition between the cask and the pad that is notcovered by the coefficient of friction 08 Ostadan Dec at para 10
3 The cold bonding may break during seismic shaking in a nonuniform pattern causinga nonuniform contact condition between the cask and the pad Ostadan Dec at para 10The coefficient of friction would not remain constant
4 The State disputes PFS Material Fact No 11 in that the two coefficients of friction02 and 08 do not effectively bracket any variation in the coefficient of friction overthe surface of the pad Ostadan Dec at IT 7 8 9 11
5 The coefficient of friction between the cask and the concrete pad is not uniformacross the surface of the cask Ostadan Dec at T 9
6 The concrete pad will not behave as a rigid surface under either static or dynamicloading Ostadan Dec at para 8
7 Due to the flexible nature of the pad the coefficient of friction will be dependentupon frictional forces Ostadan Dec at para 8
8 The contact surface between the bottom of the cask and the top of the foundation padwill not remain intact during cask loading or seismic movement Ostadan Dec at para 8
UNITED STATES OF AMERICA NUCLEAR REGULA TORY COMMISSION
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
) In the Matter of ) Docket No 72-22-ISFSI
) PRNATE FUEL STORAGE LLC ) ASLBP No 97-732-02-ISFSI (Independent Spent Fuel )
Storage Installation) ) January 21 2000
DECLARATION OF FARHANG OSTADAN PH D
I FARHANG OSTADAN hereby declare under penalty ofperjury and pursuant to 28
USC sect 1746 that
1 I hold a PhD in civil engineering from the University of
California at Berkeley My curriculum vitae listing my qualifications experience
training and publications has already been filed in this proceeding See Exhibit No2 of
the States Motion to Compel Applicant to Respond to States Fifth Set of Discovery
Requests dated December 20 1999
2 I have fifteen years experience in dynamic analysis and seismic
safety evaluation of above and underground structures and subsurface materials I coshy
developed and implemented SASSI a system for seismic soil-structure interaction
analysis currently in use by the industry worldwide I also developed a method for
liquefaction hazard analysis currently in use for critical facilities in the United States
3 I have participated in seismic studies and review of numerous
nuclear structures including Diablo Canyon Nuclear Station and the NRCEPRllarge
scale seismic experiment in Lotung Taiwan I have published numerous papers in the
area of soil structure interaction and seismic design
4 I have read the materials filed by PFS in support of its Motion for
Summary Disposition of Contention GG including the Safety Analysis Report for the
TranStor Storage Cask System rev B the TranS tor Storage Cask Seismic Stability
Analysis for PFS Site July 24 1997 (Private Utility Fuel Storage Project Cask Seismic
Tipover Analysis prepared for Sierra Nuclear Corporation by Advent Engineering
Services Inc (hereinafter Advent Report)) the PFSF Site Specific Cask Stability
Analysis for the TranStor Storage Cask September 23 1999 and the TranStor
Dynamic Response to 2000 Year Return Seismic Event Holtec Report No HI-99229S
I am familiar with the circumstances and materials in this case as they relate to
Contention GG including PFSs Safety Analysis Report I am also familiar with and have
reviewed the documents that PFS has provided to the State ofUtah concerning Utah
Contention GG PFSs responses to Discovery Requests submitted by the State and
PFSs responses to the NRC Staffs Requests for Additional Information
5 The Applicant has performed a series of simple nonlinear time
history analyses in which the interaction between the cask and the foundation pad is
modeled by frictional elements The coefficient offuction was changed in successive
analyses from 020 to 080 Soler Dec Sum Disp at ~ 9
6 Dr Alan Soler states that the coefficient of friction is a property
2
associated with a contact point between two surfaces and the value of the coefficient is
dependent on the characteristics of the two materials at the interface contact point Soler
Dec Sum Disp at ~ 7 In a declaration supporting the Applicants Response to State of
Utahs Motion to Compel Applicant to Respond to States Fifth Set of Discovery
Requests Dr Solar claims that the coefficient of friction is independent of the friction
forces Solar Dec Resp Mo Compel at ~ 10 However the coefficient of friction is
only independent of friction forces under certain circumstances
7 In justifying that the coefficient of friction is independent of
friction forces Dr Soler must assume that the contact surface between the bottom of the
cask and top of the foundation will remain intact after loading the casks on the pad and
during the seismic excitation which effectively implies that the concrete pad is rigid under
both static and dynamic loading This assumption led the Applicant to the simplifying
assumption for the dynamic analysis of the cask by using simple frictional elements at the
contact points
8 However using the Applicants parameters including the
coefficient ofthe subgrade reaction of275 kipsft3 (SAR Rev 8 at 26-35) and the pad
dimensions (SAR Rev 8 at 26-87) and the relationship described in Foundation
Analysis and Design Fourth edition Joseph Bowels McGraw Hill Company 1988
Section 97 hereto attached as Exhibit A to distinguish a flexible versus a rigid mat I
have calculated that the pad will not be rigid and in fact will deform when subjected to
cask loading Thus Dr Solers assumption that the cask pad is rigid is incorrect
3
Moreover because the pad is flexible the coefficient of friction is dependent on friction
forces and will be affected at the contact points between the cask and the pad
9 Under dynamic loading the dynamic properties of a flexible pad
are different from those of a rigid pad I The flexible behavior of the foundation pad will
amplify under the inertia of the casks on the pad Thus the coefficient of friction will not
be constant across the pad and the Applicants analysis of uniform coefficient of friction
will not bound the actual behavior of the casks and the pad
10 It is also possible that the casks on the pad could develop a cold
bonding over time The cold bonding causes a contact condition between the cask and
the pad that is not covered by the highest coefficient of friction used by the Applicant
Additionally the effect of the cold bonding is not necessarily the same as the hinge
condition that the Applicant assumed in the previous Advent analysis 2 The bonding may
break during seismic shaking in a nonuniform pattern depending on the contact stresses
causing a nonuniform contact condition between the cask and the pad
11 Within the context of Contention GG and the modeling technique
used by the Applicant and considering the realistic and flexible behavior of the pad under
1 An excellent comparison of the dynamic properties of rigid versus flexible foundation is presented by Iguchi and Luco in Dynamic response ofFlexible Rectangular Foundations on an Elastic Halfspace Journal of Earthquake Engineering and Structural dynamics 1981 Vol 9
2 The Advent Report assumed that the cask was analytically pinned at one edge and did not consider the coefficients of friction Soler Dec Sum Disp at ~ 4
4
P0011001
BOI j56C292 p C06
ootil the statIc find dy11amic loading il is my opinion (hili the 1joltec 2000 analysis relied
llpon by lhe Aptllicant till falls to considcrvarilltiOli of coelilcicm Qf friction over the
surfllce ofthc pad and the shift from static case to kinetic cnsc
12 This Declaration hils been prepared in 5UPPO( of the State of
Utahs RLlsponse to Applicants M~llion for Summary Disposition ()(Contcntion Utuh
GG and Lhe Slates nccomp~nying Statement of Msnelial ract~ and is trile and correct to
the best M my knowledge nnd beief
DATED thi~ January 21 ~woo
ATTACHMENT A
LlLJI
IlUUJ 110 t1l70
FOUNDA11Ul~ UVJVVIJ
ANALYSIS Al1J)
DESIGN Fourth Edition
Joseph E Bowles PE SE Ctmsulril1 ilIgilllerStJjrwtlre C(msullam
~1If1IrIfill~J c~mlllt(r SI(flllrt Poritl lIIimljs
McGraw-lUll Publishina Company New York St Louu SAIl Frlllciseo lullkllllld HOlloW Canebullbull
HlIMbllrs Utbon Loodon MdrW Mtldco Milan MQflJnzl New Delhi OItlaho1na Ciqo Pan Son 111amp11
sro Plo SlngporI Syc1llY Tokyo TorqllQ
I
V 1 _ v
410 FouNDATION ANALVSlS AND DI5KlN
97 CLASSICAL SOLllTION OF BEAM ON ELASTIC FOlJNDAnON
When tlexur1 rigidity oCthe [aotin iii taken into accounl a solution is used that is based on some fonn of a heam on an elEl~tic (oundaLlon This may be of the classical Winkler solution of about 1861 in which the founchulon is considered as a bed of sprins (Winkler round ation) or a nnllgteement procedure of the nex section
The classical solutions being of closed ronn are not as ~ncra in application as the finite-clement merhod The basic differential equal ion is (see Fie 9-10)
pound1 dXlJy q - k~y (9-1l)
JAN -20 OO(THU) 1018
SPJ(IAL morlNOS owp BIlAS ON f)Imc ~(lIlNIgtIlTIONS 411
TABLE)2 Cloted-form Bolldons of infinite beam on Iseric fOlndlltiQn (Fig 9middot1011)
-VI M=TBu
Q -VIC
CflrJCllnrnltuli 101141 QI tilnln Moment III CDnllllf
MJl J -k- Bu dcllcclion
P M =rrcbullbull
-I -MeQ=-1gt Q= -2- A shear
Z
The A B C IiLPd D COtlfficienLS are
A =- o~) + silll)
BJgtt c-lmiddot ~in AX
Cl~ - middot(cosx - sin ltx)
1J1~ -u COampx
where k kB In solvin the equations a variable is inLroduced
bull 4 (iii )Iii -Jill or
TabJe 9middot2 Sives the closedmiddotfonn solution of t e basic differential equations for scveralloadingll shown in Fig 9-10 ulilizing the Winkler concept It is convCJliell~ to express the trigonometric portion of the solutions sepannely as in tbe bottom of Table 9middot2
He~enyi (1946) developed equations for a load at any point along a beam (see Fig 9middot10b) mea~ured from the len end as rallows
JAN -20 00 (THU) 1018 BEl TEL415 768 4898 p 004005
412 FOlNDAT10N ANALYSIS NI) OESION
k = kiP Hncludes cffic or BJ
-----) -----0 cUM [b) Finite length beam cn elUlic
(oundation ---
--~----~gt~~-r--IJ~lt~--~~~M I ~~
Moment curve
Ii ---shy ~ Q ---~~
~ Shear curve
ta) Infillitc Icnlh beam an an elude rOllndatlan
FIGUDE 1)10 Beam on eillstic roundaticm
Y k~ (sinh ~l_ sjJl2 AL) 2 cosh AX cosu (sinh U cos la cosh)b
-ilin L cosh )(J cos lb) + (cosh It-X sin lx
+ sinh 1x cos tx) [sinh U (sin)a cosh 1b - cos ttl sinh lb)
+~j )L (sinh lQ cos)b - cosh ia sin Ah)J) (9middot12)
M a t ( hl ~ l AL) 2 sin AX sin h (sinh tL cos ~ cosb lb _ SIn I - SUI
- Sill U cosh AU WS ~iJ - l~osh 1( sinlx - sillh lx cos AX)
x [sinh)L (sin ta cosb 1b - cos )a sinh )b)
+sill )L sinh l cos ib - coshit sin ib)J (9-13)
-- TEL415 768 4898 JAN -20 OOTHUI 1018 BEl bull __ ~ bullbull nM~1gt UN ElAT1C rOU~tgtAIr)NS 411
x (sinh L cos AQ cosh Jb - sin iL cosh AQ CQS )h)
+ sinh Ax sin i( [sinh L (sin la cosh b shy cos 1Q sinh lb)
+ sin )L (liinh )a etlS h shy cosh AQ sin )b)]
The equation far the slope eof the beam at any point is not pre$ented is of little value in the design of a footing The value of x to use in the equa from the end o the beam to the point ror which the deOection moment or desired If x is less than the distance use the equations lS given and meaSUf x from C Ifx is largdf than a replace a with b in the equations and measure x from D (Fig 9middottOb) These equations may be rewritten as
Y=~A M=S and QPCk ~A
whllre the coeffioients A B and C are the values or the hyperbolic and trigonometric remainder of Eqs (9-12) to (9middot14)
It has been proposed that one could u~e U previously defined to determine if a foundation should be analyzed 011 the basis of the conventional rigid procedure Or as a beam on an elastic foundation
Rigi members (bending not influenced much by k)
(bending bcavity localized)
e 8l1tbor has found the above criteria 0 1 e app leation bocause of the infiuence or number of loads and their locations on the member
The classical solution presented here has several distinct disadviulluges over the finj[~middotelement solution presented i~ the next section such as
I Assumes weipoundhtless beam (but weight wUl be a factor when footing tends to stlparate from the soil)
2 Difficult to remove soil effect when footing tends to separate [rom soil 3 Difficult [0 account for boundary conditions orknown rotation or deflection at
seleCted points 4 Difficult to apply multiple types or loads to a foolina S Difficult to chanse footins properties of I D and B 6 Difficult to allow for change in subgrade reaclion along fOOling
Although tbe disltdvaruages are substantial iome engineeri prefer the classical beatll-onelaslic-foundation approacb over discrete element analyses Rarely the classical approach may be a better model than a discrete elemetn analysis so it is worthwhile to have access to ilii5 method of solution
P 005005
CERTIFICATE OF SERVICE -1 -i 1 - - -- -
J 1i G 7 - I t L i__ _ tJI i I F4
I hereby certify that a copy of STATE OF UTAHS RESPONSE TO THEgt00 JN 27 7 53
APPLICANTS MOTION FOR SUMMARY DISPOSITION OF UTAH CONTENTION
GG - FAILURE TO DEMONSTRATE CASK-PAD STABILITY DURING SEISMIC
EVENT FOR TRANSTOR CASKS was served on the persons listed below by electronic
mail (unless otherwise noted) with conforming copies by United States mail first class
this 21 st day of January 2000
Emile L Julian Assistant forRulemakings and Adjudications
Rulemaking amp Adjudication StaffSecretary of the CommissionU S Nuclear Regulatory CommissionWashington DC 20555E-mail hearingdocket~nrcgov(original and two copies)
G Paul Bollwerk HI ChairmanAdministrative JudgeAtomic Safety and Licensing BoardU S Nuclear Regulatory CommissionWashington DC 20555E-Mail gpb~nrcgov
Dr Jerry R KlineAdministrative JudgeAtomic Safety and Licensing BoardU S Nuclear Regulatory CommissionWashington DC 20555E-Mail jrk2nrcgovE-Mail kjerrygerolscom
Dr Peter S LamAdministrative JudgeAtomic Safety and Licensing BoardU S Nuclear Regulatory CommissionWashington DC 20555E-Mail psl~nrcgov
Sherwin E Turk EsqCatherine L Marco EsqOffice of the General Counsel
Mail Stop O-15-B-18US Nuclear Regulatory CommissionWashington DC 20555E-Mail setgnrcgovE-Mail clm~nrcgov
Jay E Silberg EsqErnest L Blake Jr EsqPaul A Gaukler EsqShaw Pittman Potts amp Trowbridge2300 N Street N WWashington DC 20037-8007E-Mail JaySilberg~shawpittmancomE-Mail ernestblakegshawpittmancomE-Mail paulgaukler~shawpittmancom
8
John Paul Kennedy Sr Esq1385 Yale AvenueSalt Lake City Utah 84105E-Mail john~kennedysorg
Joro Walker EsqLand and Water Fund of the Rockies2056 East 3300 South Street Suite ISalt Lake City Utah 84109E-Mail joro61inconnectcom
Danny Quintana EsqDanny Quintana amp Associates PC68 South Main Street Suite 600Salt Lake City Utah 84101E-Mail quintana~xmissioncom
James M CutchinAtomic Safety and Licensing Board PanelUS Nuclear Regulatory CommissionWashington DC 20555-0001E-Mail jmc3nrcgov(electronic copy only)
Office of the Commission AppellateAdjudication
Mail Stop 014-G-15U S Nuclear Regulatory CommissionWashington DC 20555
Assistant Attorney GeneralState of Utah
9
UNITED STATES OF AMERICANUCLEAR REGULATORY COMMISSION
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)_In the Matter of ) Docket No 72-22-ISFSI
)PRIVATE FUEL STORAGE LLC ) ASLBP No 97-732-02-ISFSI(Independent Spent Fuel )
Storage Installation) ) January 21 2000
STATE OF UTAHS STATEMENT OF DISPUTEDAND RELEVANT MATERIAL FACTS FOR UTAH CONTENTION GG
1 The State disputes PFS Material Fact No 10 in that 08 does not bound the highestcoefficient of friction expected to occur Ostadan Dec at para 10
2 The cask and the concrete pad may develop cold bonding Ostadan Dec para 10 Thecold bonding causes a contact condition between the cask and the pad that is notcovered by the coefficient of friction 08 Ostadan Dec at para 10
3 The cold bonding may break during seismic shaking in a nonuniform pattern causinga nonuniform contact condition between the cask and the pad Ostadan Dec at para 10The coefficient of friction would not remain constant
4 The State disputes PFS Material Fact No 11 in that the two coefficients of friction02 and 08 do not effectively bracket any variation in the coefficient of friction overthe surface of the pad Ostadan Dec at IT 7 8 9 11
5 The coefficient of friction between the cask and the concrete pad is not uniformacross the surface of the cask Ostadan Dec at T 9
6 The concrete pad will not behave as a rigid surface under either static or dynamicloading Ostadan Dec at para 8
7 Due to the flexible nature of the pad the coefficient of friction will be dependentupon frictional forces Ostadan Dec at para 8
8 The contact surface between the bottom of the cask and the top of the foundation padwill not remain intact during cask loading or seismic movement Ostadan Dec at para 8
UNITED STATES OF AMERICA NUCLEAR REGULA TORY COMMISSION
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
) In the Matter of ) Docket No 72-22-ISFSI
) PRNATE FUEL STORAGE LLC ) ASLBP No 97-732-02-ISFSI (Independent Spent Fuel )
Storage Installation) ) January 21 2000
DECLARATION OF FARHANG OSTADAN PH D
I FARHANG OSTADAN hereby declare under penalty ofperjury and pursuant to 28
USC sect 1746 that
1 I hold a PhD in civil engineering from the University of
California at Berkeley My curriculum vitae listing my qualifications experience
training and publications has already been filed in this proceeding See Exhibit No2 of
the States Motion to Compel Applicant to Respond to States Fifth Set of Discovery
Requests dated December 20 1999
2 I have fifteen years experience in dynamic analysis and seismic
safety evaluation of above and underground structures and subsurface materials I coshy
developed and implemented SASSI a system for seismic soil-structure interaction
analysis currently in use by the industry worldwide I also developed a method for
liquefaction hazard analysis currently in use for critical facilities in the United States
3 I have participated in seismic studies and review of numerous
nuclear structures including Diablo Canyon Nuclear Station and the NRCEPRllarge
scale seismic experiment in Lotung Taiwan I have published numerous papers in the
area of soil structure interaction and seismic design
4 I have read the materials filed by PFS in support of its Motion for
Summary Disposition of Contention GG including the Safety Analysis Report for the
TranStor Storage Cask System rev B the TranS tor Storage Cask Seismic Stability
Analysis for PFS Site July 24 1997 (Private Utility Fuel Storage Project Cask Seismic
Tipover Analysis prepared for Sierra Nuclear Corporation by Advent Engineering
Services Inc (hereinafter Advent Report)) the PFSF Site Specific Cask Stability
Analysis for the TranStor Storage Cask September 23 1999 and the TranStor
Dynamic Response to 2000 Year Return Seismic Event Holtec Report No HI-99229S
I am familiar with the circumstances and materials in this case as they relate to
Contention GG including PFSs Safety Analysis Report I am also familiar with and have
reviewed the documents that PFS has provided to the State ofUtah concerning Utah
Contention GG PFSs responses to Discovery Requests submitted by the State and
PFSs responses to the NRC Staffs Requests for Additional Information
5 The Applicant has performed a series of simple nonlinear time
history analyses in which the interaction between the cask and the foundation pad is
modeled by frictional elements The coefficient offuction was changed in successive
analyses from 020 to 080 Soler Dec Sum Disp at ~ 9
6 Dr Alan Soler states that the coefficient of friction is a property
2
associated with a contact point between two surfaces and the value of the coefficient is
dependent on the characteristics of the two materials at the interface contact point Soler
Dec Sum Disp at ~ 7 In a declaration supporting the Applicants Response to State of
Utahs Motion to Compel Applicant to Respond to States Fifth Set of Discovery
Requests Dr Solar claims that the coefficient of friction is independent of the friction
forces Solar Dec Resp Mo Compel at ~ 10 However the coefficient of friction is
only independent of friction forces under certain circumstances
7 In justifying that the coefficient of friction is independent of
friction forces Dr Soler must assume that the contact surface between the bottom of the
cask and top of the foundation will remain intact after loading the casks on the pad and
during the seismic excitation which effectively implies that the concrete pad is rigid under
both static and dynamic loading This assumption led the Applicant to the simplifying
assumption for the dynamic analysis of the cask by using simple frictional elements at the
contact points
8 However using the Applicants parameters including the
coefficient ofthe subgrade reaction of275 kipsft3 (SAR Rev 8 at 26-35) and the pad
dimensions (SAR Rev 8 at 26-87) and the relationship described in Foundation
Analysis and Design Fourth edition Joseph Bowels McGraw Hill Company 1988
Section 97 hereto attached as Exhibit A to distinguish a flexible versus a rigid mat I
have calculated that the pad will not be rigid and in fact will deform when subjected to
cask loading Thus Dr Solers assumption that the cask pad is rigid is incorrect
3
Moreover because the pad is flexible the coefficient of friction is dependent on friction
forces and will be affected at the contact points between the cask and the pad
9 Under dynamic loading the dynamic properties of a flexible pad
are different from those of a rigid pad I The flexible behavior of the foundation pad will
amplify under the inertia of the casks on the pad Thus the coefficient of friction will not
be constant across the pad and the Applicants analysis of uniform coefficient of friction
will not bound the actual behavior of the casks and the pad
10 It is also possible that the casks on the pad could develop a cold
bonding over time The cold bonding causes a contact condition between the cask and
the pad that is not covered by the highest coefficient of friction used by the Applicant
Additionally the effect of the cold bonding is not necessarily the same as the hinge
condition that the Applicant assumed in the previous Advent analysis 2 The bonding may
break during seismic shaking in a nonuniform pattern depending on the contact stresses
causing a nonuniform contact condition between the cask and the pad
11 Within the context of Contention GG and the modeling technique
used by the Applicant and considering the realistic and flexible behavior of the pad under
1 An excellent comparison of the dynamic properties of rigid versus flexible foundation is presented by Iguchi and Luco in Dynamic response ofFlexible Rectangular Foundations on an Elastic Halfspace Journal of Earthquake Engineering and Structural dynamics 1981 Vol 9
2 The Advent Report assumed that the cask was analytically pinned at one edge and did not consider the coefficients of friction Soler Dec Sum Disp at ~ 4
4
P0011001
BOI j56C292 p C06
ootil the statIc find dy11amic loading il is my opinion (hili the 1joltec 2000 analysis relied
llpon by lhe Aptllicant till falls to considcrvarilltiOli of coelilcicm Qf friction over the
surfllce ofthc pad and the shift from static case to kinetic cnsc
12 This Declaration hils been prepared in 5UPPO( of the State of
Utahs RLlsponse to Applicants M~llion for Summary Disposition ()(Contcntion Utuh
GG and Lhe Slates nccomp~nying Statement of Msnelial ract~ and is trile and correct to
the best M my knowledge nnd beief
DATED thi~ January 21 ~woo
ATTACHMENT A
LlLJI
IlUUJ 110 t1l70
FOUNDA11Ul~ UVJVVIJ
ANALYSIS Al1J)
DESIGN Fourth Edition
Joseph E Bowles PE SE Ctmsulril1 ilIgilllerStJjrwtlre C(msullam
~1If1IrIfill~J c~mlllt(r SI(flllrt Poritl lIIimljs
McGraw-lUll Publishina Company New York St Louu SAIl Frlllciseo lullkllllld HOlloW Canebullbull
HlIMbllrs Utbon Loodon MdrW Mtldco Milan MQflJnzl New Delhi OItlaho1na Ciqo Pan Son 111amp11
sro Plo SlngporI Syc1llY Tokyo TorqllQ
I
V 1 _ v
410 FouNDATION ANALVSlS AND DI5KlN
97 CLASSICAL SOLllTION OF BEAM ON ELASTIC FOlJNDAnON
When tlexur1 rigidity oCthe [aotin iii taken into accounl a solution is used that is based on some fonn of a heam on an elEl~tic (oundaLlon This may be of the classical Winkler solution of about 1861 in which the founchulon is considered as a bed of sprins (Winkler round ation) or a nnllgteement procedure of the nex section
The classical solutions being of closed ronn are not as ~ncra in application as the finite-clement merhod The basic differential equal ion is (see Fie 9-10)
pound1 dXlJy q - k~y (9-1l)
JAN -20 OO(THU) 1018
SPJ(IAL morlNOS owp BIlAS ON f)Imc ~(lIlNIgtIlTIONS 411
TABLE)2 Cloted-form Bolldons of infinite beam on Iseric fOlndlltiQn (Fig 9middot1011)
-VI M=TBu
Q -VIC
CflrJCllnrnltuli 101141 QI tilnln Moment III CDnllllf
MJl J -k- Bu dcllcclion
P M =rrcbullbull
-I -MeQ=-1gt Q= -2- A shear
Z
The A B C IiLPd D COtlfficienLS are
A =- o~) + silll)
BJgtt c-lmiddot ~in AX
Cl~ - middot(cosx - sin ltx)
1J1~ -u COampx
where k kB In solvin the equations a variable is inLroduced
bull 4 (iii )Iii -Jill or
TabJe 9middot2 Sives the closedmiddotfonn solution of t e basic differential equations for scveralloadingll shown in Fig 9-10 ulilizing the Winkler concept It is convCJliell~ to express the trigonometric portion of the solutions sepannely as in tbe bottom of Table 9middot2
He~enyi (1946) developed equations for a load at any point along a beam (see Fig 9middot10b) mea~ured from the len end as rallows
JAN -20 00 (THU) 1018 BEl TEL415 768 4898 p 004005
412 FOlNDAT10N ANALYSIS NI) OESION
k = kiP Hncludes cffic or BJ
-----) -----0 cUM [b) Finite length beam cn elUlic
(oundation ---
--~----~gt~~-r--IJ~lt~--~~~M I ~~
Moment curve
Ii ---shy ~ Q ---~~
~ Shear curve
ta) Infillitc Icnlh beam an an elude rOllndatlan
FIGUDE 1)10 Beam on eillstic roundaticm
Y k~ (sinh ~l_ sjJl2 AL) 2 cosh AX cosu (sinh U cos la cosh)b
-ilin L cosh )(J cos lb) + (cosh It-X sin lx
+ sinh 1x cos tx) [sinh U (sin)a cosh 1b - cos ttl sinh lb)
+~j )L (sinh lQ cos)b - cosh ia sin Ah)J) (9middot12)
M a t ( hl ~ l AL) 2 sin AX sin h (sinh tL cos ~ cosb lb _ SIn I - SUI
- Sill U cosh AU WS ~iJ - l~osh 1( sinlx - sillh lx cos AX)
x [sinh)L (sin ta cosb 1b - cos )a sinh )b)
+sill )L sinh l cos ib - coshit sin ib)J (9-13)
-- TEL415 768 4898 JAN -20 OOTHUI 1018 BEl bull __ ~ bullbull nM~1gt UN ElAT1C rOU~tgtAIr)NS 411
x (sinh L cos AQ cosh Jb - sin iL cosh AQ CQS )h)
+ sinh Ax sin i( [sinh L (sin la cosh b shy cos 1Q sinh lb)
+ sin )L (liinh )a etlS h shy cosh AQ sin )b)]
The equation far the slope eof the beam at any point is not pre$ented is of little value in the design of a footing The value of x to use in the equa from the end o the beam to the point ror which the deOection moment or desired If x is less than the distance use the equations lS given and meaSUf x from C Ifx is largdf than a replace a with b in the equations and measure x from D (Fig 9middottOb) These equations may be rewritten as
Y=~A M=S and QPCk ~A
whllre the coeffioients A B and C are the values or the hyperbolic and trigonometric remainder of Eqs (9-12) to (9middot14)
It has been proposed that one could u~e U previously defined to determine if a foundation should be analyzed 011 the basis of the conventional rigid procedure Or as a beam on an elastic foundation
Rigi members (bending not influenced much by k)
(bending bcavity localized)
e 8l1tbor has found the above criteria 0 1 e app leation bocause of the infiuence or number of loads and their locations on the member
The classical solution presented here has several distinct disadviulluges over the finj[~middotelement solution presented i~ the next section such as
I Assumes weipoundhtless beam (but weight wUl be a factor when footing tends to stlparate from the soil)
2 Difficult to remove soil effect when footing tends to separate [rom soil 3 Difficult [0 account for boundary conditions orknown rotation or deflection at
seleCted points 4 Difficult to apply multiple types or loads to a foolina S Difficult to chanse footins properties of I D and B 6 Difficult to allow for change in subgrade reaclion along fOOling
Although tbe disltdvaruages are substantial iome engineeri prefer the classical beatll-onelaslic-foundation approacb over discrete element analyses Rarely the classical approach may be a better model than a discrete elemetn analysis so it is worthwhile to have access to ilii5 method of solution
P 005005
John Paul Kennedy Sr Esq1385 Yale AvenueSalt Lake City Utah 84105E-Mail john~kennedysorg
Joro Walker EsqLand and Water Fund of the Rockies2056 East 3300 South Street Suite ISalt Lake City Utah 84109E-Mail joro61inconnectcom
Danny Quintana EsqDanny Quintana amp Associates PC68 South Main Street Suite 600Salt Lake City Utah 84101E-Mail quintana~xmissioncom
James M CutchinAtomic Safety and Licensing Board PanelUS Nuclear Regulatory CommissionWashington DC 20555-0001E-Mail jmc3nrcgov(electronic copy only)
Office of the Commission AppellateAdjudication
Mail Stop 014-G-15U S Nuclear Regulatory CommissionWashington DC 20555
Assistant Attorney GeneralState of Utah
9
UNITED STATES OF AMERICANUCLEAR REGULATORY COMMISSION
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)_In the Matter of ) Docket No 72-22-ISFSI
)PRIVATE FUEL STORAGE LLC ) ASLBP No 97-732-02-ISFSI(Independent Spent Fuel )
Storage Installation) ) January 21 2000
STATE OF UTAHS STATEMENT OF DISPUTEDAND RELEVANT MATERIAL FACTS FOR UTAH CONTENTION GG
1 The State disputes PFS Material Fact No 10 in that 08 does not bound the highestcoefficient of friction expected to occur Ostadan Dec at para 10
2 The cask and the concrete pad may develop cold bonding Ostadan Dec para 10 Thecold bonding causes a contact condition between the cask and the pad that is notcovered by the coefficient of friction 08 Ostadan Dec at para 10
3 The cold bonding may break during seismic shaking in a nonuniform pattern causinga nonuniform contact condition between the cask and the pad Ostadan Dec at para 10The coefficient of friction would not remain constant
4 The State disputes PFS Material Fact No 11 in that the two coefficients of friction02 and 08 do not effectively bracket any variation in the coefficient of friction overthe surface of the pad Ostadan Dec at IT 7 8 9 11
5 The coefficient of friction between the cask and the concrete pad is not uniformacross the surface of the cask Ostadan Dec at T 9
6 The concrete pad will not behave as a rigid surface under either static or dynamicloading Ostadan Dec at para 8
7 Due to the flexible nature of the pad the coefficient of friction will be dependentupon frictional forces Ostadan Dec at para 8
8 The contact surface between the bottom of the cask and the top of the foundation padwill not remain intact during cask loading or seismic movement Ostadan Dec at para 8
UNITED STATES OF AMERICA NUCLEAR REGULA TORY COMMISSION
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
) In the Matter of ) Docket No 72-22-ISFSI
) PRNATE FUEL STORAGE LLC ) ASLBP No 97-732-02-ISFSI (Independent Spent Fuel )
Storage Installation) ) January 21 2000
DECLARATION OF FARHANG OSTADAN PH D
I FARHANG OSTADAN hereby declare under penalty ofperjury and pursuant to 28
USC sect 1746 that
1 I hold a PhD in civil engineering from the University of
California at Berkeley My curriculum vitae listing my qualifications experience
training and publications has already been filed in this proceeding See Exhibit No2 of
the States Motion to Compel Applicant to Respond to States Fifth Set of Discovery
Requests dated December 20 1999
2 I have fifteen years experience in dynamic analysis and seismic
safety evaluation of above and underground structures and subsurface materials I coshy
developed and implemented SASSI a system for seismic soil-structure interaction
analysis currently in use by the industry worldwide I also developed a method for
liquefaction hazard analysis currently in use for critical facilities in the United States
3 I have participated in seismic studies and review of numerous
nuclear structures including Diablo Canyon Nuclear Station and the NRCEPRllarge
scale seismic experiment in Lotung Taiwan I have published numerous papers in the
area of soil structure interaction and seismic design
4 I have read the materials filed by PFS in support of its Motion for
Summary Disposition of Contention GG including the Safety Analysis Report for the
TranStor Storage Cask System rev B the TranS tor Storage Cask Seismic Stability
Analysis for PFS Site July 24 1997 (Private Utility Fuel Storage Project Cask Seismic
Tipover Analysis prepared for Sierra Nuclear Corporation by Advent Engineering
Services Inc (hereinafter Advent Report)) the PFSF Site Specific Cask Stability
Analysis for the TranStor Storage Cask September 23 1999 and the TranStor
Dynamic Response to 2000 Year Return Seismic Event Holtec Report No HI-99229S
I am familiar with the circumstances and materials in this case as they relate to
Contention GG including PFSs Safety Analysis Report I am also familiar with and have
reviewed the documents that PFS has provided to the State ofUtah concerning Utah
Contention GG PFSs responses to Discovery Requests submitted by the State and
PFSs responses to the NRC Staffs Requests for Additional Information
5 The Applicant has performed a series of simple nonlinear time
history analyses in which the interaction between the cask and the foundation pad is
modeled by frictional elements The coefficient offuction was changed in successive
analyses from 020 to 080 Soler Dec Sum Disp at ~ 9
6 Dr Alan Soler states that the coefficient of friction is a property
2
associated with a contact point between two surfaces and the value of the coefficient is
dependent on the characteristics of the two materials at the interface contact point Soler
Dec Sum Disp at ~ 7 In a declaration supporting the Applicants Response to State of
Utahs Motion to Compel Applicant to Respond to States Fifth Set of Discovery
Requests Dr Solar claims that the coefficient of friction is independent of the friction
forces Solar Dec Resp Mo Compel at ~ 10 However the coefficient of friction is
only independent of friction forces under certain circumstances
7 In justifying that the coefficient of friction is independent of
friction forces Dr Soler must assume that the contact surface between the bottom of the
cask and top of the foundation will remain intact after loading the casks on the pad and
during the seismic excitation which effectively implies that the concrete pad is rigid under
both static and dynamic loading This assumption led the Applicant to the simplifying
assumption for the dynamic analysis of the cask by using simple frictional elements at the
contact points
8 However using the Applicants parameters including the
coefficient ofthe subgrade reaction of275 kipsft3 (SAR Rev 8 at 26-35) and the pad
dimensions (SAR Rev 8 at 26-87) and the relationship described in Foundation
Analysis and Design Fourth edition Joseph Bowels McGraw Hill Company 1988
Section 97 hereto attached as Exhibit A to distinguish a flexible versus a rigid mat I
have calculated that the pad will not be rigid and in fact will deform when subjected to
cask loading Thus Dr Solers assumption that the cask pad is rigid is incorrect
3
Moreover because the pad is flexible the coefficient of friction is dependent on friction
forces and will be affected at the contact points between the cask and the pad
9 Under dynamic loading the dynamic properties of a flexible pad
are different from those of a rigid pad I The flexible behavior of the foundation pad will
amplify under the inertia of the casks on the pad Thus the coefficient of friction will not
be constant across the pad and the Applicants analysis of uniform coefficient of friction
will not bound the actual behavior of the casks and the pad
10 It is also possible that the casks on the pad could develop a cold
bonding over time The cold bonding causes a contact condition between the cask and
the pad that is not covered by the highest coefficient of friction used by the Applicant
Additionally the effect of the cold bonding is not necessarily the same as the hinge
condition that the Applicant assumed in the previous Advent analysis 2 The bonding may
break during seismic shaking in a nonuniform pattern depending on the contact stresses
causing a nonuniform contact condition between the cask and the pad
11 Within the context of Contention GG and the modeling technique
used by the Applicant and considering the realistic and flexible behavior of the pad under
1 An excellent comparison of the dynamic properties of rigid versus flexible foundation is presented by Iguchi and Luco in Dynamic response ofFlexible Rectangular Foundations on an Elastic Halfspace Journal of Earthquake Engineering and Structural dynamics 1981 Vol 9
2 The Advent Report assumed that the cask was analytically pinned at one edge and did not consider the coefficients of friction Soler Dec Sum Disp at ~ 4
4
P0011001
BOI j56C292 p C06
ootil the statIc find dy11amic loading il is my opinion (hili the 1joltec 2000 analysis relied
llpon by lhe Aptllicant till falls to considcrvarilltiOli of coelilcicm Qf friction over the
surfllce ofthc pad and the shift from static case to kinetic cnsc
12 This Declaration hils been prepared in 5UPPO( of the State of
Utahs RLlsponse to Applicants M~llion for Summary Disposition ()(Contcntion Utuh
GG and Lhe Slates nccomp~nying Statement of Msnelial ract~ and is trile and correct to
the best M my knowledge nnd beief
DATED thi~ January 21 ~woo
ATTACHMENT A
LlLJI
IlUUJ 110 t1l70
FOUNDA11Ul~ UVJVVIJ
ANALYSIS Al1J)
DESIGN Fourth Edition
Joseph E Bowles PE SE Ctmsulril1 ilIgilllerStJjrwtlre C(msullam
~1If1IrIfill~J c~mlllt(r SI(flllrt Poritl lIIimljs
McGraw-lUll Publishina Company New York St Louu SAIl Frlllciseo lullkllllld HOlloW Canebullbull
HlIMbllrs Utbon Loodon MdrW Mtldco Milan MQflJnzl New Delhi OItlaho1na Ciqo Pan Son 111amp11
sro Plo SlngporI Syc1llY Tokyo TorqllQ
I
V 1 _ v
410 FouNDATION ANALVSlS AND DI5KlN
97 CLASSICAL SOLllTION OF BEAM ON ELASTIC FOlJNDAnON
When tlexur1 rigidity oCthe [aotin iii taken into accounl a solution is used that is based on some fonn of a heam on an elEl~tic (oundaLlon This may be of the classical Winkler solution of about 1861 in which the founchulon is considered as a bed of sprins (Winkler round ation) or a nnllgteement procedure of the nex section
The classical solutions being of closed ronn are not as ~ncra in application as the finite-clement merhod The basic differential equal ion is (see Fie 9-10)
pound1 dXlJy q - k~y (9-1l)
JAN -20 OO(THU) 1018
SPJ(IAL morlNOS owp BIlAS ON f)Imc ~(lIlNIgtIlTIONS 411
TABLE)2 Cloted-form Bolldons of infinite beam on Iseric fOlndlltiQn (Fig 9middot1011)
-VI M=TBu
Q -VIC
CflrJCllnrnltuli 101141 QI tilnln Moment III CDnllllf
MJl J -k- Bu dcllcclion
P M =rrcbullbull
-I -MeQ=-1gt Q= -2- A shear
Z
The A B C IiLPd D COtlfficienLS are
A =- o~) + silll)
BJgtt c-lmiddot ~in AX
Cl~ - middot(cosx - sin ltx)
1J1~ -u COampx
where k kB In solvin the equations a variable is inLroduced
bull 4 (iii )Iii -Jill or
TabJe 9middot2 Sives the closedmiddotfonn solution of t e basic differential equations for scveralloadingll shown in Fig 9-10 ulilizing the Winkler concept It is convCJliell~ to express the trigonometric portion of the solutions sepannely as in tbe bottom of Table 9middot2
He~enyi (1946) developed equations for a load at any point along a beam (see Fig 9middot10b) mea~ured from the len end as rallows
JAN -20 00 (THU) 1018 BEl TEL415 768 4898 p 004005
412 FOlNDAT10N ANALYSIS NI) OESION
k = kiP Hncludes cffic or BJ
-----) -----0 cUM [b) Finite length beam cn elUlic
(oundation ---
--~----~gt~~-r--IJ~lt~--~~~M I ~~
Moment curve
Ii ---shy ~ Q ---~~
~ Shear curve
ta) Infillitc Icnlh beam an an elude rOllndatlan
FIGUDE 1)10 Beam on eillstic roundaticm
Y k~ (sinh ~l_ sjJl2 AL) 2 cosh AX cosu (sinh U cos la cosh)b
-ilin L cosh )(J cos lb) + (cosh It-X sin lx
+ sinh 1x cos tx) [sinh U (sin)a cosh 1b - cos ttl sinh lb)
+~j )L (sinh lQ cos)b - cosh ia sin Ah)J) (9middot12)
M a t ( hl ~ l AL) 2 sin AX sin h (sinh tL cos ~ cosb lb _ SIn I - SUI
- Sill U cosh AU WS ~iJ - l~osh 1( sinlx - sillh lx cos AX)
x [sinh)L (sin ta cosb 1b - cos )a sinh )b)
+sill )L sinh l cos ib - coshit sin ib)J (9-13)
-- TEL415 768 4898 JAN -20 OOTHUI 1018 BEl bull __ ~ bullbull nM~1gt UN ElAT1C rOU~tgtAIr)NS 411
x (sinh L cos AQ cosh Jb - sin iL cosh AQ CQS )h)
+ sinh Ax sin i( [sinh L (sin la cosh b shy cos 1Q sinh lb)
+ sin )L (liinh )a etlS h shy cosh AQ sin )b)]
The equation far the slope eof the beam at any point is not pre$ented is of little value in the design of a footing The value of x to use in the equa from the end o the beam to the point ror which the deOection moment or desired If x is less than the distance use the equations lS given and meaSUf x from C Ifx is largdf than a replace a with b in the equations and measure x from D (Fig 9middottOb) These equations may be rewritten as
Y=~A M=S and QPCk ~A
whllre the coeffioients A B and C are the values or the hyperbolic and trigonometric remainder of Eqs (9-12) to (9middot14)
It has been proposed that one could u~e U previously defined to determine if a foundation should be analyzed 011 the basis of the conventional rigid procedure Or as a beam on an elastic foundation
Rigi members (bending not influenced much by k)
(bending bcavity localized)
e 8l1tbor has found the above criteria 0 1 e app leation bocause of the infiuence or number of loads and their locations on the member
The classical solution presented here has several distinct disadviulluges over the finj[~middotelement solution presented i~ the next section such as
I Assumes weipoundhtless beam (but weight wUl be a factor when footing tends to stlparate from the soil)
2 Difficult to remove soil effect when footing tends to separate [rom soil 3 Difficult [0 account for boundary conditions orknown rotation or deflection at
seleCted points 4 Difficult to apply multiple types or loads to a foolina S Difficult to chanse footins properties of I D and B 6 Difficult to allow for change in subgrade reaclion along fOOling
Although tbe disltdvaruages are substantial iome engineeri prefer the classical beatll-onelaslic-foundation approacb over discrete element analyses Rarely the classical approach may be a better model than a discrete elemetn analysis so it is worthwhile to have access to ilii5 method of solution
P 005005
UNITED STATES OF AMERICANUCLEAR REGULATORY COMMISSION
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)_In the Matter of ) Docket No 72-22-ISFSI
)PRIVATE FUEL STORAGE LLC ) ASLBP No 97-732-02-ISFSI(Independent Spent Fuel )
Storage Installation) ) January 21 2000
STATE OF UTAHS STATEMENT OF DISPUTEDAND RELEVANT MATERIAL FACTS FOR UTAH CONTENTION GG
1 The State disputes PFS Material Fact No 10 in that 08 does not bound the highestcoefficient of friction expected to occur Ostadan Dec at para 10
2 The cask and the concrete pad may develop cold bonding Ostadan Dec para 10 Thecold bonding causes a contact condition between the cask and the pad that is notcovered by the coefficient of friction 08 Ostadan Dec at para 10
3 The cold bonding may break during seismic shaking in a nonuniform pattern causinga nonuniform contact condition between the cask and the pad Ostadan Dec at para 10The coefficient of friction would not remain constant
4 The State disputes PFS Material Fact No 11 in that the two coefficients of friction02 and 08 do not effectively bracket any variation in the coefficient of friction overthe surface of the pad Ostadan Dec at IT 7 8 9 11
5 The coefficient of friction between the cask and the concrete pad is not uniformacross the surface of the cask Ostadan Dec at T 9
6 The concrete pad will not behave as a rigid surface under either static or dynamicloading Ostadan Dec at para 8
7 Due to the flexible nature of the pad the coefficient of friction will be dependentupon frictional forces Ostadan Dec at para 8
8 The contact surface between the bottom of the cask and the top of the foundation padwill not remain intact during cask loading or seismic movement Ostadan Dec at para 8
UNITED STATES OF AMERICA NUCLEAR REGULA TORY COMMISSION
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
) In the Matter of ) Docket No 72-22-ISFSI
) PRNATE FUEL STORAGE LLC ) ASLBP No 97-732-02-ISFSI (Independent Spent Fuel )
Storage Installation) ) January 21 2000
DECLARATION OF FARHANG OSTADAN PH D
I FARHANG OSTADAN hereby declare under penalty ofperjury and pursuant to 28
USC sect 1746 that
1 I hold a PhD in civil engineering from the University of
California at Berkeley My curriculum vitae listing my qualifications experience
training and publications has already been filed in this proceeding See Exhibit No2 of
the States Motion to Compel Applicant to Respond to States Fifth Set of Discovery
Requests dated December 20 1999
2 I have fifteen years experience in dynamic analysis and seismic
safety evaluation of above and underground structures and subsurface materials I coshy
developed and implemented SASSI a system for seismic soil-structure interaction
analysis currently in use by the industry worldwide I also developed a method for
liquefaction hazard analysis currently in use for critical facilities in the United States
3 I have participated in seismic studies and review of numerous
nuclear structures including Diablo Canyon Nuclear Station and the NRCEPRllarge
scale seismic experiment in Lotung Taiwan I have published numerous papers in the
area of soil structure interaction and seismic design
4 I have read the materials filed by PFS in support of its Motion for
Summary Disposition of Contention GG including the Safety Analysis Report for the
TranStor Storage Cask System rev B the TranS tor Storage Cask Seismic Stability
Analysis for PFS Site July 24 1997 (Private Utility Fuel Storage Project Cask Seismic
Tipover Analysis prepared for Sierra Nuclear Corporation by Advent Engineering
Services Inc (hereinafter Advent Report)) the PFSF Site Specific Cask Stability
Analysis for the TranStor Storage Cask September 23 1999 and the TranStor
Dynamic Response to 2000 Year Return Seismic Event Holtec Report No HI-99229S
I am familiar with the circumstances and materials in this case as they relate to
Contention GG including PFSs Safety Analysis Report I am also familiar with and have
reviewed the documents that PFS has provided to the State ofUtah concerning Utah
Contention GG PFSs responses to Discovery Requests submitted by the State and
PFSs responses to the NRC Staffs Requests for Additional Information
5 The Applicant has performed a series of simple nonlinear time
history analyses in which the interaction between the cask and the foundation pad is
modeled by frictional elements The coefficient offuction was changed in successive
analyses from 020 to 080 Soler Dec Sum Disp at ~ 9
6 Dr Alan Soler states that the coefficient of friction is a property
2
associated with a contact point between two surfaces and the value of the coefficient is
dependent on the characteristics of the two materials at the interface contact point Soler
Dec Sum Disp at ~ 7 In a declaration supporting the Applicants Response to State of
Utahs Motion to Compel Applicant to Respond to States Fifth Set of Discovery
Requests Dr Solar claims that the coefficient of friction is independent of the friction
forces Solar Dec Resp Mo Compel at ~ 10 However the coefficient of friction is
only independent of friction forces under certain circumstances
7 In justifying that the coefficient of friction is independent of
friction forces Dr Soler must assume that the contact surface between the bottom of the
cask and top of the foundation will remain intact after loading the casks on the pad and
during the seismic excitation which effectively implies that the concrete pad is rigid under
both static and dynamic loading This assumption led the Applicant to the simplifying
assumption for the dynamic analysis of the cask by using simple frictional elements at the
contact points
8 However using the Applicants parameters including the
coefficient ofthe subgrade reaction of275 kipsft3 (SAR Rev 8 at 26-35) and the pad
dimensions (SAR Rev 8 at 26-87) and the relationship described in Foundation
Analysis and Design Fourth edition Joseph Bowels McGraw Hill Company 1988
Section 97 hereto attached as Exhibit A to distinguish a flexible versus a rigid mat I
have calculated that the pad will not be rigid and in fact will deform when subjected to
cask loading Thus Dr Solers assumption that the cask pad is rigid is incorrect
3
Moreover because the pad is flexible the coefficient of friction is dependent on friction
forces and will be affected at the contact points between the cask and the pad
9 Under dynamic loading the dynamic properties of a flexible pad
are different from those of a rigid pad I The flexible behavior of the foundation pad will
amplify under the inertia of the casks on the pad Thus the coefficient of friction will not
be constant across the pad and the Applicants analysis of uniform coefficient of friction
will not bound the actual behavior of the casks and the pad
10 It is also possible that the casks on the pad could develop a cold
bonding over time The cold bonding causes a contact condition between the cask and
the pad that is not covered by the highest coefficient of friction used by the Applicant
Additionally the effect of the cold bonding is not necessarily the same as the hinge
condition that the Applicant assumed in the previous Advent analysis 2 The bonding may
break during seismic shaking in a nonuniform pattern depending on the contact stresses
causing a nonuniform contact condition between the cask and the pad
11 Within the context of Contention GG and the modeling technique
used by the Applicant and considering the realistic and flexible behavior of the pad under
1 An excellent comparison of the dynamic properties of rigid versus flexible foundation is presented by Iguchi and Luco in Dynamic response ofFlexible Rectangular Foundations on an Elastic Halfspace Journal of Earthquake Engineering and Structural dynamics 1981 Vol 9
2 The Advent Report assumed that the cask was analytically pinned at one edge and did not consider the coefficients of friction Soler Dec Sum Disp at ~ 4
4
P0011001
BOI j56C292 p C06
ootil the statIc find dy11amic loading il is my opinion (hili the 1joltec 2000 analysis relied
llpon by lhe Aptllicant till falls to considcrvarilltiOli of coelilcicm Qf friction over the
surfllce ofthc pad and the shift from static case to kinetic cnsc
12 This Declaration hils been prepared in 5UPPO( of the State of
Utahs RLlsponse to Applicants M~llion for Summary Disposition ()(Contcntion Utuh
GG and Lhe Slates nccomp~nying Statement of Msnelial ract~ and is trile and correct to
the best M my knowledge nnd beief
DATED thi~ January 21 ~woo
ATTACHMENT A
LlLJI
IlUUJ 110 t1l70
FOUNDA11Ul~ UVJVVIJ
ANALYSIS Al1J)
DESIGN Fourth Edition
Joseph E Bowles PE SE Ctmsulril1 ilIgilllerStJjrwtlre C(msullam
~1If1IrIfill~J c~mlllt(r SI(flllrt Poritl lIIimljs
McGraw-lUll Publishina Company New York St Louu SAIl Frlllciseo lullkllllld HOlloW Canebullbull
HlIMbllrs Utbon Loodon MdrW Mtldco Milan MQflJnzl New Delhi OItlaho1na Ciqo Pan Son 111amp11
sro Plo SlngporI Syc1llY Tokyo TorqllQ
I
V 1 _ v
410 FouNDATION ANALVSlS AND DI5KlN
97 CLASSICAL SOLllTION OF BEAM ON ELASTIC FOlJNDAnON
When tlexur1 rigidity oCthe [aotin iii taken into accounl a solution is used that is based on some fonn of a heam on an elEl~tic (oundaLlon This may be of the classical Winkler solution of about 1861 in which the founchulon is considered as a bed of sprins (Winkler round ation) or a nnllgteement procedure of the nex section
The classical solutions being of closed ronn are not as ~ncra in application as the finite-clement merhod The basic differential equal ion is (see Fie 9-10)
pound1 dXlJy q - k~y (9-1l)
JAN -20 OO(THU) 1018
SPJ(IAL morlNOS owp BIlAS ON f)Imc ~(lIlNIgtIlTIONS 411
TABLE)2 Cloted-form Bolldons of infinite beam on Iseric fOlndlltiQn (Fig 9middot1011)
-VI M=TBu
Q -VIC
CflrJCllnrnltuli 101141 QI tilnln Moment III CDnllllf
MJl J -k- Bu dcllcclion
P M =rrcbullbull
-I -MeQ=-1gt Q= -2- A shear
Z
The A B C IiLPd D COtlfficienLS are
A =- o~) + silll)
BJgtt c-lmiddot ~in AX
Cl~ - middot(cosx - sin ltx)
1J1~ -u COampx
where k kB In solvin the equations a variable is inLroduced
bull 4 (iii )Iii -Jill or
TabJe 9middot2 Sives the closedmiddotfonn solution of t e basic differential equations for scveralloadingll shown in Fig 9-10 ulilizing the Winkler concept It is convCJliell~ to express the trigonometric portion of the solutions sepannely as in tbe bottom of Table 9middot2
He~enyi (1946) developed equations for a load at any point along a beam (see Fig 9middot10b) mea~ured from the len end as rallows
JAN -20 00 (THU) 1018 BEl TEL415 768 4898 p 004005
412 FOlNDAT10N ANALYSIS NI) OESION
k = kiP Hncludes cffic or BJ
-----) -----0 cUM [b) Finite length beam cn elUlic
(oundation ---
--~----~gt~~-r--IJ~lt~--~~~M I ~~
Moment curve
Ii ---shy ~ Q ---~~
~ Shear curve
ta) Infillitc Icnlh beam an an elude rOllndatlan
FIGUDE 1)10 Beam on eillstic roundaticm
Y k~ (sinh ~l_ sjJl2 AL) 2 cosh AX cosu (sinh U cos la cosh)b
-ilin L cosh )(J cos lb) + (cosh It-X sin lx
+ sinh 1x cos tx) [sinh U (sin)a cosh 1b - cos ttl sinh lb)
+~j )L (sinh lQ cos)b - cosh ia sin Ah)J) (9middot12)
M a t ( hl ~ l AL) 2 sin AX sin h (sinh tL cos ~ cosb lb _ SIn I - SUI
- Sill U cosh AU WS ~iJ - l~osh 1( sinlx - sillh lx cos AX)
x [sinh)L (sin ta cosb 1b - cos )a sinh )b)
+sill )L sinh l cos ib - coshit sin ib)J (9-13)
-- TEL415 768 4898 JAN -20 OOTHUI 1018 BEl bull __ ~ bullbull nM~1gt UN ElAT1C rOU~tgtAIr)NS 411
x (sinh L cos AQ cosh Jb - sin iL cosh AQ CQS )h)
+ sinh Ax sin i( [sinh L (sin la cosh b shy cos 1Q sinh lb)
+ sin )L (liinh )a etlS h shy cosh AQ sin )b)]
The equation far the slope eof the beam at any point is not pre$ented is of little value in the design of a footing The value of x to use in the equa from the end o the beam to the point ror which the deOection moment or desired If x is less than the distance use the equations lS given and meaSUf x from C Ifx is largdf than a replace a with b in the equations and measure x from D (Fig 9middottOb) These equations may be rewritten as
Y=~A M=S and QPCk ~A
whllre the coeffioients A B and C are the values or the hyperbolic and trigonometric remainder of Eqs (9-12) to (9middot14)
It has been proposed that one could u~e U previously defined to determine if a foundation should be analyzed 011 the basis of the conventional rigid procedure Or as a beam on an elastic foundation
Rigi members (bending not influenced much by k)
(bending bcavity localized)
e 8l1tbor has found the above criteria 0 1 e app leation bocause of the infiuence or number of loads and their locations on the member
The classical solution presented here has several distinct disadviulluges over the finj[~middotelement solution presented i~ the next section such as
I Assumes weipoundhtless beam (but weight wUl be a factor when footing tends to stlparate from the soil)
2 Difficult to remove soil effect when footing tends to separate [rom soil 3 Difficult [0 account for boundary conditions orknown rotation or deflection at
seleCted points 4 Difficult to apply multiple types or loads to a foolina S Difficult to chanse footins properties of I D and B 6 Difficult to allow for change in subgrade reaclion along fOOling
Although tbe disltdvaruages are substantial iome engineeri prefer the classical beatll-onelaslic-foundation approacb over discrete element analyses Rarely the classical approach may be a better model than a discrete elemetn analysis so it is worthwhile to have access to ilii5 method of solution
P 005005
UNITED STATES OF AMERICA NUCLEAR REGULA TORY COMMISSION
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
) In the Matter of ) Docket No 72-22-ISFSI
) PRNATE FUEL STORAGE LLC ) ASLBP No 97-732-02-ISFSI (Independent Spent Fuel )
Storage Installation) ) January 21 2000
DECLARATION OF FARHANG OSTADAN PH D
I FARHANG OSTADAN hereby declare under penalty ofperjury and pursuant to 28
USC sect 1746 that
1 I hold a PhD in civil engineering from the University of
California at Berkeley My curriculum vitae listing my qualifications experience
training and publications has already been filed in this proceeding See Exhibit No2 of
the States Motion to Compel Applicant to Respond to States Fifth Set of Discovery
Requests dated December 20 1999
2 I have fifteen years experience in dynamic analysis and seismic
safety evaluation of above and underground structures and subsurface materials I coshy
developed and implemented SASSI a system for seismic soil-structure interaction
analysis currently in use by the industry worldwide I also developed a method for
liquefaction hazard analysis currently in use for critical facilities in the United States
3 I have participated in seismic studies and review of numerous
nuclear structures including Diablo Canyon Nuclear Station and the NRCEPRllarge
scale seismic experiment in Lotung Taiwan I have published numerous papers in the
area of soil structure interaction and seismic design
4 I have read the materials filed by PFS in support of its Motion for
Summary Disposition of Contention GG including the Safety Analysis Report for the
TranStor Storage Cask System rev B the TranS tor Storage Cask Seismic Stability
Analysis for PFS Site July 24 1997 (Private Utility Fuel Storage Project Cask Seismic
Tipover Analysis prepared for Sierra Nuclear Corporation by Advent Engineering
Services Inc (hereinafter Advent Report)) the PFSF Site Specific Cask Stability
Analysis for the TranStor Storage Cask September 23 1999 and the TranStor
Dynamic Response to 2000 Year Return Seismic Event Holtec Report No HI-99229S
I am familiar with the circumstances and materials in this case as they relate to
Contention GG including PFSs Safety Analysis Report I am also familiar with and have
reviewed the documents that PFS has provided to the State ofUtah concerning Utah
Contention GG PFSs responses to Discovery Requests submitted by the State and
PFSs responses to the NRC Staffs Requests for Additional Information
5 The Applicant has performed a series of simple nonlinear time
history analyses in which the interaction between the cask and the foundation pad is
modeled by frictional elements The coefficient offuction was changed in successive
analyses from 020 to 080 Soler Dec Sum Disp at ~ 9
6 Dr Alan Soler states that the coefficient of friction is a property
2
associated with a contact point between two surfaces and the value of the coefficient is
dependent on the characteristics of the two materials at the interface contact point Soler
Dec Sum Disp at ~ 7 In a declaration supporting the Applicants Response to State of
Utahs Motion to Compel Applicant to Respond to States Fifth Set of Discovery
Requests Dr Solar claims that the coefficient of friction is independent of the friction
forces Solar Dec Resp Mo Compel at ~ 10 However the coefficient of friction is
only independent of friction forces under certain circumstances
7 In justifying that the coefficient of friction is independent of
friction forces Dr Soler must assume that the contact surface between the bottom of the
cask and top of the foundation will remain intact after loading the casks on the pad and
during the seismic excitation which effectively implies that the concrete pad is rigid under
both static and dynamic loading This assumption led the Applicant to the simplifying
assumption for the dynamic analysis of the cask by using simple frictional elements at the
contact points
8 However using the Applicants parameters including the
coefficient ofthe subgrade reaction of275 kipsft3 (SAR Rev 8 at 26-35) and the pad
dimensions (SAR Rev 8 at 26-87) and the relationship described in Foundation
Analysis and Design Fourth edition Joseph Bowels McGraw Hill Company 1988
Section 97 hereto attached as Exhibit A to distinguish a flexible versus a rigid mat I
have calculated that the pad will not be rigid and in fact will deform when subjected to
cask loading Thus Dr Solers assumption that the cask pad is rigid is incorrect
3
Moreover because the pad is flexible the coefficient of friction is dependent on friction
forces and will be affected at the contact points between the cask and the pad
9 Under dynamic loading the dynamic properties of a flexible pad
are different from those of a rigid pad I The flexible behavior of the foundation pad will
amplify under the inertia of the casks on the pad Thus the coefficient of friction will not
be constant across the pad and the Applicants analysis of uniform coefficient of friction
will not bound the actual behavior of the casks and the pad
10 It is also possible that the casks on the pad could develop a cold
bonding over time The cold bonding causes a contact condition between the cask and
the pad that is not covered by the highest coefficient of friction used by the Applicant
Additionally the effect of the cold bonding is not necessarily the same as the hinge
condition that the Applicant assumed in the previous Advent analysis 2 The bonding may
break during seismic shaking in a nonuniform pattern depending on the contact stresses
causing a nonuniform contact condition between the cask and the pad
11 Within the context of Contention GG and the modeling technique
used by the Applicant and considering the realistic and flexible behavior of the pad under
1 An excellent comparison of the dynamic properties of rigid versus flexible foundation is presented by Iguchi and Luco in Dynamic response ofFlexible Rectangular Foundations on an Elastic Halfspace Journal of Earthquake Engineering and Structural dynamics 1981 Vol 9
2 The Advent Report assumed that the cask was analytically pinned at one edge and did not consider the coefficients of friction Soler Dec Sum Disp at ~ 4
4
P0011001
BOI j56C292 p C06
ootil the statIc find dy11amic loading il is my opinion (hili the 1joltec 2000 analysis relied
llpon by lhe Aptllicant till falls to considcrvarilltiOli of coelilcicm Qf friction over the
surfllce ofthc pad and the shift from static case to kinetic cnsc
12 This Declaration hils been prepared in 5UPPO( of the State of
Utahs RLlsponse to Applicants M~llion for Summary Disposition ()(Contcntion Utuh
GG and Lhe Slates nccomp~nying Statement of Msnelial ract~ and is trile and correct to
the best M my knowledge nnd beief
DATED thi~ January 21 ~woo
ATTACHMENT A
LlLJI
IlUUJ 110 t1l70
FOUNDA11Ul~ UVJVVIJ
ANALYSIS Al1J)
DESIGN Fourth Edition
Joseph E Bowles PE SE Ctmsulril1 ilIgilllerStJjrwtlre C(msullam
~1If1IrIfill~J c~mlllt(r SI(flllrt Poritl lIIimljs
McGraw-lUll Publishina Company New York St Louu SAIl Frlllciseo lullkllllld HOlloW Canebullbull
HlIMbllrs Utbon Loodon MdrW Mtldco Milan MQflJnzl New Delhi OItlaho1na Ciqo Pan Son 111amp11
sro Plo SlngporI Syc1llY Tokyo TorqllQ
I
V 1 _ v
410 FouNDATION ANALVSlS AND DI5KlN
97 CLASSICAL SOLllTION OF BEAM ON ELASTIC FOlJNDAnON
When tlexur1 rigidity oCthe [aotin iii taken into accounl a solution is used that is based on some fonn of a heam on an elEl~tic (oundaLlon This may be of the classical Winkler solution of about 1861 in which the founchulon is considered as a bed of sprins (Winkler round ation) or a nnllgteement procedure of the nex section
The classical solutions being of closed ronn are not as ~ncra in application as the finite-clement merhod The basic differential equal ion is (see Fie 9-10)
pound1 dXlJy q - k~y (9-1l)
JAN -20 OO(THU) 1018
SPJ(IAL morlNOS owp BIlAS ON f)Imc ~(lIlNIgtIlTIONS 411
TABLE)2 Cloted-form Bolldons of infinite beam on Iseric fOlndlltiQn (Fig 9middot1011)
-VI M=TBu
Q -VIC
CflrJCllnrnltuli 101141 QI tilnln Moment III CDnllllf
MJl J -k- Bu dcllcclion
P M =rrcbullbull
-I -MeQ=-1gt Q= -2- A shear
Z
The A B C IiLPd D COtlfficienLS are
A =- o~) + silll)
BJgtt c-lmiddot ~in AX
Cl~ - middot(cosx - sin ltx)
1J1~ -u COampx
where k kB In solvin the equations a variable is inLroduced
bull 4 (iii )Iii -Jill or
TabJe 9middot2 Sives the closedmiddotfonn solution of t e basic differential equations for scveralloadingll shown in Fig 9-10 ulilizing the Winkler concept It is convCJliell~ to express the trigonometric portion of the solutions sepannely as in tbe bottom of Table 9middot2
He~enyi (1946) developed equations for a load at any point along a beam (see Fig 9middot10b) mea~ured from the len end as rallows
JAN -20 00 (THU) 1018 BEl TEL415 768 4898 p 004005
412 FOlNDAT10N ANALYSIS NI) OESION
k = kiP Hncludes cffic or BJ
-----) -----0 cUM [b) Finite length beam cn elUlic
(oundation ---
--~----~gt~~-r--IJ~lt~--~~~M I ~~
Moment curve
Ii ---shy ~ Q ---~~
~ Shear curve
ta) Infillitc Icnlh beam an an elude rOllndatlan
FIGUDE 1)10 Beam on eillstic roundaticm
Y k~ (sinh ~l_ sjJl2 AL) 2 cosh AX cosu (sinh U cos la cosh)b
-ilin L cosh )(J cos lb) + (cosh It-X sin lx
+ sinh 1x cos tx) [sinh U (sin)a cosh 1b - cos ttl sinh lb)
+~j )L (sinh lQ cos)b - cosh ia sin Ah)J) (9middot12)
M a t ( hl ~ l AL) 2 sin AX sin h (sinh tL cos ~ cosb lb _ SIn I - SUI
- Sill U cosh AU WS ~iJ - l~osh 1( sinlx - sillh lx cos AX)
x [sinh)L (sin ta cosb 1b - cos )a sinh )b)
+sill )L sinh l cos ib - coshit sin ib)J (9-13)
-- TEL415 768 4898 JAN -20 OOTHUI 1018 BEl bull __ ~ bullbull nM~1gt UN ElAT1C rOU~tgtAIr)NS 411
x (sinh L cos AQ cosh Jb - sin iL cosh AQ CQS )h)
+ sinh Ax sin i( [sinh L (sin la cosh b shy cos 1Q sinh lb)
+ sin )L (liinh )a etlS h shy cosh AQ sin )b)]
The equation far the slope eof the beam at any point is not pre$ented is of little value in the design of a footing The value of x to use in the equa from the end o the beam to the point ror which the deOection moment or desired If x is less than the distance use the equations lS given and meaSUf x from C Ifx is largdf than a replace a with b in the equations and measure x from D (Fig 9middottOb) These equations may be rewritten as
Y=~A M=S and QPCk ~A
whllre the coeffioients A B and C are the values or the hyperbolic and trigonometric remainder of Eqs (9-12) to (9middot14)
It has been proposed that one could u~e U previously defined to determine if a foundation should be analyzed 011 the basis of the conventional rigid procedure Or as a beam on an elastic foundation
Rigi members (bending not influenced much by k)
(bending bcavity localized)
e 8l1tbor has found the above criteria 0 1 e app leation bocause of the infiuence or number of loads and their locations on the member
The classical solution presented here has several distinct disadviulluges over the finj[~middotelement solution presented i~ the next section such as
I Assumes weipoundhtless beam (but weight wUl be a factor when footing tends to stlparate from the soil)
2 Difficult to remove soil effect when footing tends to separate [rom soil 3 Difficult [0 account for boundary conditions orknown rotation or deflection at
seleCted points 4 Difficult to apply multiple types or loads to a foolina S Difficult to chanse footins properties of I D and B 6 Difficult to allow for change in subgrade reaclion along fOOling
Although tbe disltdvaruages are substantial iome engineeri prefer the classical beatll-onelaslic-foundation approacb over discrete element analyses Rarely the classical approach may be a better model than a discrete elemetn analysis so it is worthwhile to have access to ilii5 method of solution
P 005005
nuclear structures including Diablo Canyon Nuclear Station and the NRCEPRllarge
scale seismic experiment in Lotung Taiwan I have published numerous papers in the
area of soil structure interaction and seismic design
4 I have read the materials filed by PFS in support of its Motion for
Summary Disposition of Contention GG including the Safety Analysis Report for the
TranStor Storage Cask System rev B the TranS tor Storage Cask Seismic Stability
Analysis for PFS Site July 24 1997 (Private Utility Fuel Storage Project Cask Seismic
Tipover Analysis prepared for Sierra Nuclear Corporation by Advent Engineering
Services Inc (hereinafter Advent Report)) the PFSF Site Specific Cask Stability
Analysis for the TranStor Storage Cask September 23 1999 and the TranStor
Dynamic Response to 2000 Year Return Seismic Event Holtec Report No HI-99229S
I am familiar with the circumstances and materials in this case as they relate to
Contention GG including PFSs Safety Analysis Report I am also familiar with and have
reviewed the documents that PFS has provided to the State ofUtah concerning Utah
Contention GG PFSs responses to Discovery Requests submitted by the State and
PFSs responses to the NRC Staffs Requests for Additional Information
5 The Applicant has performed a series of simple nonlinear time
history analyses in which the interaction between the cask and the foundation pad is
modeled by frictional elements The coefficient offuction was changed in successive
analyses from 020 to 080 Soler Dec Sum Disp at ~ 9
6 Dr Alan Soler states that the coefficient of friction is a property
2
associated with a contact point between two surfaces and the value of the coefficient is
dependent on the characteristics of the two materials at the interface contact point Soler
Dec Sum Disp at ~ 7 In a declaration supporting the Applicants Response to State of
Utahs Motion to Compel Applicant to Respond to States Fifth Set of Discovery
Requests Dr Solar claims that the coefficient of friction is independent of the friction
forces Solar Dec Resp Mo Compel at ~ 10 However the coefficient of friction is
only independent of friction forces under certain circumstances
7 In justifying that the coefficient of friction is independent of
friction forces Dr Soler must assume that the contact surface between the bottom of the
cask and top of the foundation will remain intact after loading the casks on the pad and
during the seismic excitation which effectively implies that the concrete pad is rigid under
both static and dynamic loading This assumption led the Applicant to the simplifying
assumption for the dynamic analysis of the cask by using simple frictional elements at the
contact points
8 However using the Applicants parameters including the
coefficient ofthe subgrade reaction of275 kipsft3 (SAR Rev 8 at 26-35) and the pad
dimensions (SAR Rev 8 at 26-87) and the relationship described in Foundation
Analysis and Design Fourth edition Joseph Bowels McGraw Hill Company 1988
Section 97 hereto attached as Exhibit A to distinguish a flexible versus a rigid mat I
have calculated that the pad will not be rigid and in fact will deform when subjected to
cask loading Thus Dr Solers assumption that the cask pad is rigid is incorrect
3
Moreover because the pad is flexible the coefficient of friction is dependent on friction
forces and will be affected at the contact points between the cask and the pad
9 Under dynamic loading the dynamic properties of a flexible pad
are different from those of a rigid pad I The flexible behavior of the foundation pad will
amplify under the inertia of the casks on the pad Thus the coefficient of friction will not
be constant across the pad and the Applicants analysis of uniform coefficient of friction
will not bound the actual behavior of the casks and the pad
10 It is also possible that the casks on the pad could develop a cold
bonding over time The cold bonding causes a contact condition between the cask and
the pad that is not covered by the highest coefficient of friction used by the Applicant
Additionally the effect of the cold bonding is not necessarily the same as the hinge
condition that the Applicant assumed in the previous Advent analysis 2 The bonding may
break during seismic shaking in a nonuniform pattern depending on the contact stresses
causing a nonuniform contact condition between the cask and the pad
11 Within the context of Contention GG and the modeling technique
used by the Applicant and considering the realistic and flexible behavior of the pad under
1 An excellent comparison of the dynamic properties of rigid versus flexible foundation is presented by Iguchi and Luco in Dynamic response ofFlexible Rectangular Foundations on an Elastic Halfspace Journal of Earthquake Engineering and Structural dynamics 1981 Vol 9
2 The Advent Report assumed that the cask was analytically pinned at one edge and did not consider the coefficients of friction Soler Dec Sum Disp at ~ 4
4
P0011001
BOI j56C292 p C06
ootil the statIc find dy11amic loading il is my opinion (hili the 1joltec 2000 analysis relied
llpon by lhe Aptllicant till falls to considcrvarilltiOli of coelilcicm Qf friction over the
surfllce ofthc pad and the shift from static case to kinetic cnsc
12 This Declaration hils been prepared in 5UPPO( of the State of
Utahs RLlsponse to Applicants M~llion for Summary Disposition ()(Contcntion Utuh
GG and Lhe Slates nccomp~nying Statement of Msnelial ract~ and is trile and correct to
the best M my knowledge nnd beief
DATED thi~ January 21 ~woo
ATTACHMENT A
LlLJI
IlUUJ 110 t1l70
FOUNDA11Ul~ UVJVVIJ
ANALYSIS Al1J)
DESIGN Fourth Edition
Joseph E Bowles PE SE Ctmsulril1 ilIgilllerStJjrwtlre C(msullam
~1If1IrIfill~J c~mlllt(r SI(flllrt Poritl lIIimljs
McGraw-lUll Publishina Company New York St Louu SAIl Frlllciseo lullkllllld HOlloW Canebullbull
HlIMbllrs Utbon Loodon MdrW Mtldco Milan MQflJnzl New Delhi OItlaho1na Ciqo Pan Son 111amp11
sro Plo SlngporI Syc1llY Tokyo TorqllQ
I
V 1 _ v
410 FouNDATION ANALVSlS AND DI5KlN
97 CLASSICAL SOLllTION OF BEAM ON ELASTIC FOlJNDAnON
When tlexur1 rigidity oCthe [aotin iii taken into accounl a solution is used that is based on some fonn of a heam on an elEl~tic (oundaLlon This may be of the classical Winkler solution of about 1861 in which the founchulon is considered as a bed of sprins (Winkler round ation) or a nnllgteement procedure of the nex section
The classical solutions being of closed ronn are not as ~ncra in application as the finite-clement merhod The basic differential equal ion is (see Fie 9-10)
pound1 dXlJy q - k~y (9-1l)
JAN -20 OO(THU) 1018
SPJ(IAL morlNOS owp BIlAS ON f)Imc ~(lIlNIgtIlTIONS 411
TABLE)2 Cloted-form Bolldons of infinite beam on Iseric fOlndlltiQn (Fig 9middot1011)
-VI M=TBu
Q -VIC
CflrJCllnrnltuli 101141 QI tilnln Moment III CDnllllf
MJl J -k- Bu dcllcclion
P M =rrcbullbull
-I -MeQ=-1gt Q= -2- A shear
Z
The A B C IiLPd D COtlfficienLS are
A =- o~) + silll)
BJgtt c-lmiddot ~in AX
Cl~ - middot(cosx - sin ltx)
1J1~ -u COampx
where k kB In solvin the equations a variable is inLroduced
bull 4 (iii )Iii -Jill or
TabJe 9middot2 Sives the closedmiddotfonn solution of t e basic differential equations for scveralloadingll shown in Fig 9-10 ulilizing the Winkler concept It is convCJliell~ to express the trigonometric portion of the solutions sepannely as in tbe bottom of Table 9middot2
He~enyi (1946) developed equations for a load at any point along a beam (see Fig 9middot10b) mea~ured from the len end as rallows
JAN -20 00 (THU) 1018 BEl TEL415 768 4898 p 004005
412 FOlNDAT10N ANALYSIS NI) OESION
k = kiP Hncludes cffic or BJ
-----) -----0 cUM [b) Finite length beam cn elUlic
(oundation ---
--~----~gt~~-r--IJ~lt~--~~~M I ~~
Moment curve
Ii ---shy ~ Q ---~~
~ Shear curve
ta) Infillitc Icnlh beam an an elude rOllndatlan
FIGUDE 1)10 Beam on eillstic roundaticm
Y k~ (sinh ~l_ sjJl2 AL) 2 cosh AX cosu (sinh U cos la cosh)b
-ilin L cosh )(J cos lb) + (cosh It-X sin lx
+ sinh 1x cos tx) [sinh U (sin)a cosh 1b - cos ttl sinh lb)
+~j )L (sinh lQ cos)b - cosh ia sin Ah)J) (9middot12)
M a t ( hl ~ l AL) 2 sin AX sin h (sinh tL cos ~ cosb lb _ SIn I - SUI
- Sill U cosh AU WS ~iJ - l~osh 1( sinlx - sillh lx cos AX)
x [sinh)L (sin ta cosb 1b - cos )a sinh )b)
+sill )L sinh l cos ib - coshit sin ib)J (9-13)
-- TEL415 768 4898 JAN -20 OOTHUI 1018 BEl bull __ ~ bullbull nM~1gt UN ElAT1C rOU~tgtAIr)NS 411
x (sinh L cos AQ cosh Jb - sin iL cosh AQ CQS )h)
+ sinh Ax sin i( [sinh L (sin la cosh b shy cos 1Q sinh lb)
+ sin )L (liinh )a etlS h shy cosh AQ sin )b)]
The equation far the slope eof the beam at any point is not pre$ented is of little value in the design of a footing The value of x to use in the equa from the end o the beam to the point ror which the deOection moment or desired If x is less than the distance use the equations lS given and meaSUf x from C Ifx is largdf than a replace a with b in the equations and measure x from D (Fig 9middottOb) These equations may be rewritten as
Y=~A M=S and QPCk ~A
whllre the coeffioients A B and C are the values or the hyperbolic and trigonometric remainder of Eqs (9-12) to (9middot14)
It has been proposed that one could u~e U previously defined to determine if a foundation should be analyzed 011 the basis of the conventional rigid procedure Or as a beam on an elastic foundation
Rigi members (bending not influenced much by k)
(bending bcavity localized)
e 8l1tbor has found the above criteria 0 1 e app leation bocause of the infiuence or number of loads and their locations on the member
The classical solution presented here has several distinct disadviulluges over the finj[~middotelement solution presented i~ the next section such as
I Assumes weipoundhtless beam (but weight wUl be a factor when footing tends to stlparate from the soil)
2 Difficult to remove soil effect when footing tends to separate [rom soil 3 Difficult [0 account for boundary conditions orknown rotation or deflection at
seleCted points 4 Difficult to apply multiple types or loads to a foolina S Difficult to chanse footins properties of I D and B 6 Difficult to allow for change in subgrade reaclion along fOOling
Although tbe disltdvaruages are substantial iome engineeri prefer the classical beatll-onelaslic-foundation approacb over discrete element analyses Rarely the classical approach may be a better model than a discrete elemetn analysis so it is worthwhile to have access to ilii5 method of solution
P 005005
associated with a contact point between two surfaces and the value of the coefficient is
dependent on the characteristics of the two materials at the interface contact point Soler
Dec Sum Disp at ~ 7 In a declaration supporting the Applicants Response to State of
Utahs Motion to Compel Applicant to Respond to States Fifth Set of Discovery
Requests Dr Solar claims that the coefficient of friction is independent of the friction
forces Solar Dec Resp Mo Compel at ~ 10 However the coefficient of friction is
only independent of friction forces under certain circumstances
7 In justifying that the coefficient of friction is independent of
friction forces Dr Soler must assume that the contact surface between the bottom of the
cask and top of the foundation will remain intact after loading the casks on the pad and
during the seismic excitation which effectively implies that the concrete pad is rigid under
both static and dynamic loading This assumption led the Applicant to the simplifying
assumption for the dynamic analysis of the cask by using simple frictional elements at the
contact points
8 However using the Applicants parameters including the
coefficient ofthe subgrade reaction of275 kipsft3 (SAR Rev 8 at 26-35) and the pad
dimensions (SAR Rev 8 at 26-87) and the relationship described in Foundation
Analysis and Design Fourth edition Joseph Bowels McGraw Hill Company 1988
Section 97 hereto attached as Exhibit A to distinguish a flexible versus a rigid mat I
have calculated that the pad will not be rigid and in fact will deform when subjected to
cask loading Thus Dr Solers assumption that the cask pad is rigid is incorrect
3
Moreover because the pad is flexible the coefficient of friction is dependent on friction
forces and will be affected at the contact points between the cask and the pad
9 Under dynamic loading the dynamic properties of a flexible pad
are different from those of a rigid pad I The flexible behavior of the foundation pad will
amplify under the inertia of the casks on the pad Thus the coefficient of friction will not
be constant across the pad and the Applicants analysis of uniform coefficient of friction
will not bound the actual behavior of the casks and the pad
10 It is also possible that the casks on the pad could develop a cold
bonding over time The cold bonding causes a contact condition between the cask and
the pad that is not covered by the highest coefficient of friction used by the Applicant
Additionally the effect of the cold bonding is not necessarily the same as the hinge
condition that the Applicant assumed in the previous Advent analysis 2 The bonding may
break during seismic shaking in a nonuniform pattern depending on the contact stresses
causing a nonuniform contact condition between the cask and the pad
11 Within the context of Contention GG and the modeling technique
used by the Applicant and considering the realistic and flexible behavior of the pad under
1 An excellent comparison of the dynamic properties of rigid versus flexible foundation is presented by Iguchi and Luco in Dynamic response ofFlexible Rectangular Foundations on an Elastic Halfspace Journal of Earthquake Engineering and Structural dynamics 1981 Vol 9
2 The Advent Report assumed that the cask was analytically pinned at one edge and did not consider the coefficients of friction Soler Dec Sum Disp at ~ 4
4
P0011001
BOI j56C292 p C06
ootil the statIc find dy11amic loading il is my opinion (hili the 1joltec 2000 analysis relied
llpon by lhe Aptllicant till falls to considcrvarilltiOli of coelilcicm Qf friction over the
surfllce ofthc pad and the shift from static case to kinetic cnsc
12 This Declaration hils been prepared in 5UPPO( of the State of
Utahs RLlsponse to Applicants M~llion for Summary Disposition ()(Contcntion Utuh
GG and Lhe Slates nccomp~nying Statement of Msnelial ract~ and is trile and correct to
the best M my knowledge nnd beief
DATED thi~ January 21 ~woo
ATTACHMENT A
LlLJI
IlUUJ 110 t1l70
FOUNDA11Ul~ UVJVVIJ
ANALYSIS Al1J)
DESIGN Fourth Edition
Joseph E Bowles PE SE Ctmsulril1 ilIgilllerStJjrwtlre C(msullam
~1If1IrIfill~J c~mlllt(r SI(flllrt Poritl lIIimljs
McGraw-lUll Publishina Company New York St Louu SAIl Frlllciseo lullkllllld HOlloW Canebullbull
HlIMbllrs Utbon Loodon MdrW Mtldco Milan MQflJnzl New Delhi OItlaho1na Ciqo Pan Son 111amp11
sro Plo SlngporI Syc1llY Tokyo TorqllQ
I
V 1 _ v
410 FouNDATION ANALVSlS AND DI5KlN
97 CLASSICAL SOLllTION OF BEAM ON ELASTIC FOlJNDAnON
When tlexur1 rigidity oCthe [aotin iii taken into accounl a solution is used that is based on some fonn of a heam on an elEl~tic (oundaLlon This may be of the classical Winkler solution of about 1861 in which the founchulon is considered as a bed of sprins (Winkler round ation) or a nnllgteement procedure of the nex section
The classical solutions being of closed ronn are not as ~ncra in application as the finite-clement merhod The basic differential equal ion is (see Fie 9-10)
pound1 dXlJy q - k~y (9-1l)
JAN -20 OO(THU) 1018
SPJ(IAL morlNOS owp BIlAS ON f)Imc ~(lIlNIgtIlTIONS 411
TABLE)2 Cloted-form Bolldons of infinite beam on Iseric fOlndlltiQn (Fig 9middot1011)
-VI M=TBu
Q -VIC
CflrJCllnrnltuli 101141 QI tilnln Moment III CDnllllf
MJl J -k- Bu dcllcclion
P M =rrcbullbull
-I -MeQ=-1gt Q= -2- A shear
Z
The A B C IiLPd D COtlfficienLS are
A =- o~) + silll)
BJgtt c-lmiddot ~in AX
Cl~ - middot(cosx - sin ltx)
1J1~ -u COampx
where k kB In solvin the equations a variable is inLroduced
bull 4 (iii )Iii -Jill or
TabJe 9middot2 Sives the closedmiddotfonn solution of t e basic differential equations for scveralloadingll shown in Fig 9-10 ulilizing the Winkler concept It is convCJliell~ to express the trigonometric portion of the solutions sepannely as in tbe bottom of Table 9middot2
He~enyi (1946) developed equations for a load at any point along a beam (see Fig 9middot10b) mea~ured from the len end as rallows
JAN -20 00 (THU) 1018 BEl TEL415 768 4898 p 004005
412 FOlNDAT10N ANALYSIS NI) OESION
k = kiP Hncludes cffic or BJ
-----) -----0 cUM [b) Finite length beam cn elUlic
(oundation ---
--~----~gt~~-r--IJ~lt~--~~~M I ~~
Moment curve
Ii ---shy ~ Q ---~~
~ Shear curve
ta) Infillitc Icnlh beam an an elude rOllndatlan
FIGUDE 1)10 Beam on eillstic roundaticm
Y k~ (sinh ~l_ sjJl2 AL) 2 cosh AX cosu (sinh U cos la cosh)b
-ilin L cosh )(J cos lb) + (cosh It-X sin lx
+ sinh 1x cos tx) [sinh U (sin)a cosh 1b - cos ttl sinh lb)
+~j )L (sinh lQ cos)b - cosh ia sin Ah)J) (9middot12)
M a t ( hl ~ l AL) 2 sin AX sin h (sinh tL cos ~ cosb lb _ SIn I - SUI
- Sill U cosh AU WS ~iJ - l~osh 1( sinlx - sillh lx cos AX)
x [sinh)L (sin ta cosb 1b - cos )a sinh )b)
+sill )L sinh l cos ib - coshit sin ib)J (9-13)
-- TEL415 768 4898 JAN -20 OOTHUI 1018 BEl bull __ ~ bullbull nM~1gt UN ElAT1C rOU~tgtAIr)NS 411
x (sinh L cos AQ cosh Jb - sin iL cosh AQ CQS )h)
+ sinh Ax sin i( [sinh L (sin la cosh b shy cos 1Q sinh lb)
+ sin )L (liinh )a etlS h shy cosh AQ sin )b)]
The equation far the slope eof the beam at any point is not pre$ented is of little value in the design of a footing The value of x to use in the equa from the end o the beam to the point ror which the deOection moment or desired If x is less than the distance use the equations lS given and meaSUf x from C Ifx is largdf than a replace a with b in the equations and measure x from D (Fig 9middottOb) These equations may be rewritten as
Y=~A M=S and QPCk ~A
whllre the coeffioients A B and C are the values or the hyperbolic and trigonometric remainder of Eqs (9-12) to (9middot14)
It has been proposed that one could u~e U previously defined to determine if a foundation should be analyzed 011 the basis of the conventional rigid procedure Or as a beam on an elastic foundation
Rigi members (bending not influenced much by k)
(bending bcavity localized)
e 8l1tbor has found the above criteria 0 1 e app leation bocause of the infiuence or number of loads and their locations on the member
The classical solution presented here has several distinct disadviulluges over the finj[~middotelement solution presented i~ the next section such as
I Assumes weipoundhtless beam (but weight wUl be a factor when footing tends to stlparate from the soil)
2 Difficult to remove soil effect when footing tends to separate [rom soil 3 Difficult [0 account for boundary conditions orknown rotation or deflection at
seleCted points 4 Difficult to apply multiple types or loads to a foolina S Difficult to chanse footins properties of I D and B 6 Difficult to allow for change in subgrade reaclion along fOOling
Although tbe disltdvaruages are substantial iome engineeri prefer the classical beatll-onelaslic-foundation approacb over discrete element analyses Rarely the classical approach may be a better model than a discrete elemetn analysis so it is worthwhile to have access to ilii5 method of solution
P 005005
Moreover because the pad is flexible the coefficient of friction is dependent on friction
forces and will be affected at the contact points between the cask and the pad
9 Under dynamic loading the dynamic properties of a flexible pad
are different from those of a rigid pad I The flexible behavior of the foundation pad will
amplify under the inertia of the casks on the pad Thus the coefficient of friction will not
be constant across the pad and the Applicants analysis of uniform coefficient of friction
will not bound the actual behavior of the casks and the pad
10 It is also possible that the casks on the pad could develop a cold
bonding over time The cold bonding causes a contact condition between the cask and
the pad that is not covered by the highest coefficient of friction used by the Applicant
Additionally the effect of the cold bonding is not necessarily the same as the hinge
condition that the Applicant assumed in the previous Advent analysis 2 The bonding may
break during seismic shaking in a nonuniform pattern depending on the contact stresses
causing a nonuniform contact condition between the cask and the pad
11 Within the context of Contention GG and the modeling technique
used by the Applicant and considering the realistic and flexible behavior of the pad under
1 An excellent comparison of the dynamic properties of rigid versus flexible foundation is presented by Iguchi and Luco in Dynamic response ofFlexible Rectangular Foundations on an Elastic Halfspace Journal of Earthquake Engineering and Structural dynamics 1981 Vol 9
2 The Advent Report assumed that the cask was analytically pinned at one edge and did not consider the coefficients of friction Soler Dec Sum Disp at ~ 4
4
P0011001
BOI j56C292 p C06
ootil the statIc find dy11amic loading il is my opinion (hili the 1joltec 2000 analysis relied
llpon by lhe Aptllicant till falls to considcrvarilltiOli of coelilcicm Qf friction over the
surfllce ofthc pad and the shift from static case to kinetic cnsc
12 This Declaration hils been prepared in 5UPPO( of the State of
Utahs RLlsponse to Applicants M~llion for Summary Disposition ()(Contcntion Utuh
GG and Lhe Slates nccomp~nying Statement of Msnelial ract~ and is trile and correct to
the best M my knowledge nnd beief
DATED thi~ January 21 ~woo
ATTACHMENT A
LlLJI
IlUUJ 110 t1l70
FOUNDA11Ul~ UVJVVIJ
ANALYSIS Al1J)
DESIGN Fourth Edition
Joseph E Bowles PE SE Ctmsulril1 ilIgilllerStJjrwtlre C(msullam
~1If1IrIfill~J c~mlllt(r SI(flllrt Poritl lIIimljs
McGraw-lUll Publishina Company New York St Louu SAIl Frlllciseo lullkllllld HOlloW Canebullbull
HlIMbllrs Utbon Loodon MdrW Mtldco Milan MQflJnzl New Delhi OItlaho1na Ciqo Pan Son 111amp11
sro Plo SlngporI Syc1llY Tokyo TorqllQ
I
V 1 _ v
410 FouNDATION ANALVSlS AND DI5KlN
97 CLASSICAL SOLllTION OF BEAM ON ELASTIC FOlJNDAnON
When tlexur1 rigidity oCthe [aotin iii taken into accounl a solution is used that is based on some fonn of a heam on an elEl~tic (oundaLlon This may be of the classical Winkler solution of about 1861 in which the founchulon is considered as a bed of sprins (Winkler round ation) or a nnllgteement procedure of the nex section
The classical solutions being of closed ronn are not as ~ncra in application as the finite-clement merhod The basic differential equal ion is (see Fie 9-10)
pound1 dXlJy q - k~y (9-1l)
JAN -20 OO(THU) 1018
SPJ(IAL morlNOS owp BIlAS ON f)Imc ~(lIlNIgtIlTIONS 411
TABLE)2 Cloted-form Bolldons of infinite beam on Iseric fOlndlltiQn (Fig 9middot1011)
-VI M=TBu
Q -VIC
CflrJCllnrnltuli 101141 QI tilnln Moment III CDnllllf
MJl J -k- Bu dcllcclion
P M =rrcbullbull
-I -MeQ=-1gt Q= -2- A shear
Z
The A B C IiLPd D COtlfficienLS are
A =- o~) + silll)
BJgtt c-lmiddot ~in AX
Cl~ - middot(cosx - sin ltx)
1J1~ -u COampx
where k kB In solvin the equations a variable is inLroduced
bull 4 (iii )Iii -Jill or
TabJe 9middot2 Sives the closedmiddotfonn solution of t e basic differential equations for scveralloadingll shown in Fig 9-10 ulilizing the Winkler concept It is convCJliell~ to express the trigonometric portion of the solutions sepannely as in tbe bottom of Table 9middot2
He~enyi (1946) developed equations for a load at any point along a beam (see Fig 9middot10b) mea~ured from the len end as rallows
JAN -20 00 (THU) 1018 BEl TEL415 768 4898 p 004005
412 FOlNDAT10N ANALYSIS NI) OESION
k = kiP Hncludes cffic or BJ
-----) -----0 cUM [b) Finite length beam cn elUlic
(oundation ---
--~----~gt~~-r--IJ~lt~--~~~M I ~~
Moment curve
Ii ---shy ~ Q ---~~
~ Shear curve
ta) Infillitc Icnlh beam an an elude rOllndatlan
FIGUDE 1)10 Beam on eillstic roundaticm
Y k~ (sinh ~l_ sjJl2 AL) 2 cosh AX cosu (sinh U cos la cosh)b
-ilin L cosh )(J cos lb) + (cosh It-X sin lx
+ sinh 1x cos tx) [sinh U (sin)a cosh 1b - cos ttl sinh lb)
+~j )L (sinh lQ cos)b - cosh ia sin Ah)J) (9middot12)
M a t ( hl ~ l AL) 2 sin AX sin h (sinh tL cos ~ cosb lb _ SIn I - SUI
- Sill U cosh AU WS ~iJ - l~osh 1( sinlx - sillh lx cos AX)
x [sinh)L (sin ta cosb 1b - cos )a sinh )b)
+sill )L sinh l cos ib - coshit sin ib)J (9-13)
-- TEL415 768 4898 JAN -20 OOTHUI 1018 BEl bull __ ~ bullbull nM~1gt UN ElAT1C rOU~tgtAIr)NS 411
x (sinh L cos AQ cosh Jb - sin iL cosh AQ CQS )h)
+ sinh Ax sin i( [sinh L (sin la cosh b shy cos 1Q sinh lb)
+ sin )L (liinh )a etlS h shy cosh AQ sin )b)]
The equation far the slope eof the beam at any point is not pre$ented is of little value in the design of a footing The value of x to use in the equa from the end o the beam to the point ror which the deOection moment or desired If x is less than the distance use the equations lS given and meaSUf x from C Ifx is largdf than a replace a with b in the equations and measure x from D (Fig 9middottOb) These equations may be rewritten as
Y=~A M=S and QPCk ~A
whllre the coeffioients A B and C are the values or the hyperbolic and trigonometric remainder of Eqs (9-12) to (9middot14)
It has been proposed that one could u~e U previously defined to determine if a foundation should be analyzed 011 the basis of the conventional rigid procedure Or as a beam on an elastic foundation
Rigi members (bending not influenced much by k)
(bending bcavity localized)
e 8l1tbor has found the above criteria 0 1 e app leation bocause of the infiuence or number of loads and their locations on the member
The classical solution presented here has several distinct disadviulluges over the finj[~middotelement solution presented i~ the next section such as
I Assumes weipoundhtless beam (but weight wUl be a factor when footing tends to stlparate from the soil)
2 Difficult to remove soil effect when footing tends to separate [rom soil 3 Difficult [0 account for boundary conditions orknown rotation or deflection at
seleCted points 4 Difficult to apply multiple types or loads to a foolina S Difficult to chanse footins properties of I D and B 6 Difficult to allow for change in subgrade reaclion along fOOling
Although tbe disltdvaruages are substantial iome engineeri prefer the classical beatll-onelaslic-foundation approacb over discrete element analyses Rarely the classical approach may be a better model than a discrete elemetn analysis so it is worthwhile to have access to ilii5 method of solution
P 005005
P0011001
BOI j56C292 p C06
ootil the statIc find dy11amic loading il is my opinion (hili the 1joltec 2000 analysis relied
llpon by lhe Aptllicant till falls to considcrvarilltiOli of coelilcicm Qf friction over the
surfllce ofthc pad and the shift from static case to kinetic cnsc
12 This Declaration hils been prepared in 5UPPO( of the State of
Utahs RLlsponse to Applicants M~llion for Summary Disposition ()(Contcntion Utuh
GG and Lhe Slates nccomp~nying Statement of Msnelial ract~ and is trile and correct to
the best M my knowledge nnd beief
DATED thi~ January 21 ~woo
ATTACHMENT A
LlLJI
IlUUJ 110 t1l70
FOUNDA11Ul~ UVJVVIJ
ANALYSIS Al1J)
DESIGN Fourth Edition
Joseph E Bowles PE SE Ctmsulril1 ilIgilllerStJjrwtlre C(msullam
~1If1IrIfill~J c~mlllt(r SI(flllrt Poritl lIIimljs
McGraw-lUll Publishina Company New York St Louu SAIl Frlllciseo lullkllllld HOlloW Canebullbull
HlIMbllrs Utbon Loodon MdrW Mtldco Milan MQflJnzl New Delhi OItlaho1na Ciqo Pan Son 111amp11
sro Plo SlngporI Syc1llY Tokyo TorqllQ
I
V 1 _ v
410 FouNDATION ANALVSlS AND DI5KlN
97 CLASSICAL SOLllTION OF BEAM ON ELASTIC FOlJNDAnON
When tlexur1 rigidity oCthe [aotin iii taken into accounl a solution is used that is based on some fonn of a heam on an elEl~tic (oundaLlon This may be of the classical Winkler solution of about 1861 in which the founchulon is considered as a bed of sprins (Winkler round ation) or a nnllgteement procedure of the nex section
The classical solutions being of closed ronn are not as ~ncra in application as the finite-clement merhod The basic differential equal ion is (see Fie 9-10)
pound1 dXlJy q - k~y (9-1l)
JAN -20 OO(THU) 1018
SPJ(IAL morlNOS owp BIlAS ON f)Imc ~(lIlNIgtIlTIONS 411
TABLE)2 Cloted-form Bolldons of infinite beam on Iseric fOlndlltiQn (Fig 9middot1011)
-VI M=TBu
Q -VIC
CflrJCllnrnltuli 101141 QI tilnln Moment III CDnllllf
MJl J -k- Bu dcllcclion
P M =rrcbullbull
-I -MeQ=-1gt Q= -2- A shear
Z
The A B C IiLPd D COtlfficienLS are
A =- o~) + silll)
BJgtt c-lmiddot ~in AX
Cl~ - middot(cosx - sin ltx)
1J1~ -u COampx
where k kB In solvin the equations a variable is inLroduced
bull 4 (iii )Iii -Jill or
TabJe 9middot2 Sives the closedmiddotfonn solution of t e basic differential equations for scveralloadingll shown in Fig 9-10 ulilizing the Winkler concept It is convCJliell~ to express the trigonometric portion of the solutions sepannely as in tbe bottom of Table 9middot2
He~enyi (1946) developed equations for a load at any point along a beam (see Fig 9middot10b) mea~ured from the len end as rallows
JAN -20 00 (THU) 1018 BEl TEL415 768 4898 p 004005
412 FOlNDAT10N ANALYSIS NI) OESION
k = kiP Hncludes cffic or BJ
-----) -----0 cUM [b) Finite length beam cn elUlic
(oundation ---
--~----~gt~~-r--IJ~lt~--~~~M I ~~
Moment curve
Ii ---shy ~ Q ---~~
~ Shear curve
ta) Infillitc Icnlh beam an an elude rOllndatlan
FIGUDE 1)10 Beam on eillstic roundaticm
Y k~ (sinh ~l_ sjJl2 AL) 2 cosh AX cosu (sinh U cos la cosh)b
-ilin L cosh )(J cos lb) + (cosh It-X sin lx
+ sinh 1x cos tx) [sinh U (sin)a cosh 1b - cos ttl sinh lb)
+~j )L (sinh lQ cos)b - cosh ia sin Ah)J) (9middot12)
M a t ( hl ~ l AL) 2 sin AX sin h (sinh tL cos ~ cosb lb _ SIn I - SUI
- Sill U cosh AU WS ~iJ - l~osh 1( sinlx - sillh lx cos AX)
x [sinh)L (sin ta cosb 1b - cos )a sinh )b)
+sill )L sinh l cos ib - coshit sin ib)J (9-13)
-- TEL415 768 4898 JAN -20 OOTHUI 1018 BEl bull __ ~ bullbull nM~1gt UN ElAT1C rOU~tgtAIr)NS 411
x (sinh L cos AQ cosh Jb - sin iL cosh AQ CQS )h)
+ sinh Ax sin i( [sinh L (sin la cosh b shy cos 1Q sinh lb)
+ sin )L (liinh )a etlS h shy cosh AQ sin )b)]
The equation far the slope eof the beam at any point is not pre$ented is of little value in the design of a footing The value of x to use in the equa from the end o the beam to the point ror which the deOection moment or desired If x is less than the distance use the equations lS given and meaSUf x from C Ifx is largdf than a replace a with b in the equations and measure x from D (Fig 9middottOb) These equations may be rewritten as
Y=~A M=S and QPCk ~A
whllre the coeffioients A B and C are the values or the hyperbolic and trigonometric remainder of Eqs (9-12) to (9middot14)
It has been proposed that one could u~e U previously defined to determine if a foundation should be analyzed 011 the basis of the conventional rigid procedure Or as a beam on an elastic foundation
Rigi members (bending not influenced much by k)
(bending bcavity localized)
e 8l1tbor has found the above criteria 0 1 e app leation bocause of the infiuence or number of loads and their locations on the member
The classical solution presented here has several distinct disadviulluges over the finj[~middotelement solution presented i~ the next section such as
I Assumes weipoundhtless beam (but weight wUl be a factor when footing tends to stlparate from the soil)
2 Difficult to remove soil effect when footing tends to separate [rom soil 3 Difficult [0 account for boundary conditions orknown rotation or deflection at
seleCted points 4 Difficult to apply multiple types or loads to a foolina S Difficult to chanse footins properties of I D and B 6 Difficult to allow for change in subgrade reaclion along fOOling
Although tbe disltdvaruages are substantial iome engineeri prefer the classical beatll-onelaslic-foundation approacb over discrete element analyses Rarely the classical approach may be a better model than a discrete elemetn analysis so it is worthwhile to have access to ilii5 method of solution
P 005005
ATTACHMENT A
LlLJI
IlUUJ 110 t1l70
FOUNDA11Ul~ UVJVVIJ
ANALYSIS Al1J)
DESIGN Fourth Edition
Joseph E Bowles PE SE Ctmsulril1 ilIgilllerStJjrwtlre C(msullam
~1If1IrIfill~J c~mlllt(r SI(flllrt Poritl lIIimljs
McGraw-lUll Publishina Company New York St Louu SAIl Frlllciseo lullkllllld HOlloW Canebullbull
HlIMbllrs Utbon Loodon MdrW Mtldco Milan MQflJnzl New Delhi OItlaho1na Ciqo Pan Son 111amp11
sro Plo SlngporI Syc1llY Tokyo TorqllQ
I
V 1 _ v
410 FouNDATION ANALVSlS AND DI5KlN
97 CLASSICAL SOLllTION OF BEAM ON ELASTIC FOlJNDAnON
When tlexur1 rigidity oCthe [aotin iii taken into accounl a solution is used that is based on some fonn of a heam on an elEl~tic (oundaLlon This may be of the classical Winkler solution of about 1861 in which the founchulon is considered as a bed of sprins (Winkler round ation) or a nnllgteement procedure of the nex section
The classical solutions being of closed ronn are not as ~ncra in application as the finite-clement merhod The basic differential equal ion is (see Fie 9-10)
pound1 dXlJy q - k~y (9-1l)
JAN -20 OO(THU) 1018
SPJ(IAL morlNOS owp BIlAS ON f)Imc ~(lIlNIgtIlTIONS 411
TABLE)2 Cloted-form Bolldons of infinite beam on Iseric fOlndlltiQn (Fig 9middot1011)
-VI M=TBu
Q -VIC
CflrJCllnrnltuli 101141 QI tilnln Moment III CDnllllf
MJl J -k- Bu dcllcclion
P M =rrcbullbull
-I -MeQ=-1gt Q= -2- A shear
Z
The A B C IiLPd D COtlfficienLS are
A =- o~) + silll)
BJgtt c-lmiddot ~in AX
Cl~ - middot(cosx - sin ltx)
1J1~ -u COampx
where k kB In solvin the equations a variable is inLroduced
bull 4 (iii )Iii -Jill or
TabJe 9middot2 Sives the closedmiddotfonn solution of t e basic differential equations for scveralloadingll shown in Fig 9-10 ulilizing the Winkler concept It is convCJliell~ to express the trigonometric portion of the solutions sepannely as in tbe bottom of Table 9middot2
He~enyi (1946) developed equations for a load at any point along a beam (see Fig 9middot10b) mea~ured from the len end as rallows
JAN -20 00 (THU) 1018 BEl TEL415 768 4898 p 004005
412 FOlNDAT10N ANALYSIS NI) OESION
k = kiP Hncludes cffic or BJ
-----) -----0 cUM [b) Finite length beam cn elUlic
(oundation ---
--~----~gt~~-r--IJ~lt~--~~~M I ~~
Moment curve
Ii ---shy ~ Q ---~~
~ Shear curve
ta) Infillitc Icnlh beam an an elude rOllndatlan
FIGUDE 1)10 Beam on eillstic roundaticm
Y k~ (sinh ~l_ sjJl2 AL) 2 cosh AX cosu (sinh U cos la cosh)b
-ilin L cosh )(J cos lb) + (cosh It-X sin lx
+ sinh 1x cos tx) [sinh U (sin)a cosh 1b - cos ttl sinh lb)
+~j )L (sinh lQ cos)b - cosh ia sin Ah)J) (9middot12)
M a t ( hl ~ l AL) 2 sin AX sin h (sinh tL cos ~ cosb lb _ SIn I - SUI
- Sill U cosh AU WS ~iJ - l~osh 1( sinlx - sillh lx cos AX)
x [sinh)L (sin ta cosb 1b - cos )a sinh )b)
+sill )L sinh l cos ib - coshit sin ib)J (9-13)
-- TEL415 768 4898 JAN -20 OOTHUI 1018 BEl bull __ ~ bullbull nM~1gt UN ElAT1C rOU~tgtAIr)NS 411
x (sinh L cos AQ cosh Jb - sin iL cosh AQ CQS )h)
+ sinh Ax sin i( [sinh L (sin la cosh b shy cos 1Q sinh lb)
+ sin )L (liinh )a etlS h shy cosh AQ sin )b)]
The equation far the slope eof the beam at any point is not pre$ented is of little value in the design of a footing The value of x to use in the equa from the end o the beam to the point ror which the deOection moment or desired If x is less than the distance use the equations lS given and meaSUf x from C Ifx is largdf than a replace a with b in the equations and measure x from D (Fig 9middottOb) These equations may be rewritten as
Y=~A M=S and QPCk ~A
whllre the coeffioients A B and C are the values or the hyperbolic and trigonometric remainder of Eqs (9-12) to (9middot14)
It has been proposed that one could u~e U previously defined to determine if a foundation should be analyzed 011 the basis of the conventional rigid procedure Or as a beam on an elastic foundation
Rigi members (bending not influenced much by k)
(bending bcavity localized)
e 8l1tbor has found the above criteria 0 1 e app leation bocause of the infiuence or number of loads and their locations on the member
The classical solution presented here has several distinct disadviulluges over the finj[~middotelement solution presented i~ the next section such as
I Assumes weipoundhtless beam (but weight wUl be a factor when footing tends to stlparate from the soil)
2 Difficult to remove soil effect when footing tends to separate [rom soil 3 Difficult [0 account for boundary conditions orknown rotation or deflection at
seleCted points 4 Difficult to apply multiple types or loads to a foolina S Difficult to chanse footins properties of I D and B 6 Difficult to allow for change in subgrade reaclion along fOOling
Although tbe disltdvaruages are substantial iome engineeri prefer the classical beatll-onelaslic-foundation approacb over discrete element analyses Rarely the classical approach may be a better model than a discrete elemetn analysis so it is worthwhile to have access to ilii5 method of solution
P 005005
LlLJI
IlUUJ 110 t1l70
FOUNDA11Ul~ UVJVVIJ
ANALYSIS Al1J)
DESIGN Fourth Edition
Joseph E Bowles PE SE Ctmsulril1 ilIgilllerStJjrwtlre C(msullam
~1If1IrIfill~J c~mlllt(r SI(flllrt Poritl lIIimljs
McGraw-lUll Publishina Company New York St Louu SAIl Frlllciseo lullkllllld HOlloW Canebullbull
HlIMbllrs Utbon Loodon MdrW Mtldco Milan MQflJnzl New Delhi OItlaho1na Ciqo Pan Son 111amp11
sro Plo SlngporI Syc1llY Tokyo TorqllQ
I
V 1 _ v
410 FouNDATION ANALVSlS AND DI5KlN
97 CLASSICAL SOLllTION OF BEAM ON ELASTIC FOlJNDAnON
When tlexur1 rigidity oCthe [aotin iii taken into accounl a solution is used that is based on some fonn of a heam on an elEl~tic (oundaLlon This may be of the classical Winkler solution of about 1861 in which the founchulon is considered as a bed of sprins (Winkler round ation) or a nnllgteement procedure of the nex section
The classical solutions being of closed ronn are not as ~ncra in application as the finite-clement merhod The basic differential equal ion is (see Fie 9-10)
pound1 dXlJy q - k~y (9-1l)
JAN -20 OO(THU) 1018
SPJ(IAL morlNOS owp BIlAS ON f)Imc ~(lIlNIgtIlTIONS 411
TABLE)2 Cloted-form Bolldons of infinite beam on Iseric fOlndlltiQn (Fig 9middot1011)
-VI M=TBu
Q -VIC
CflrJCllnrnltuli 101141 QI tilnln Moment III CDnllllf
MJl J -k- Bu dcllcclion
P M =rrcbullbull
-I -MeQ=-1gt Q= -2- A shear
Z
The A B C IiLPd D COtlfficienLS are
A =- o~) + silll)
BJgtt c-lmiddot ~in AX
Cl~ - middot(cosx - sin ltx)
1J1~ -u COampx
where k kB In solvin the equations a variable is inLroduced
bull 4 (iii )Iii -Jill or
TabJe 9middot2 Sives the closedmiddotfonn solution of t e basic differential equations for scveralloadingll shown in Fig 9-10 ulilizing the Winkler concept It is convCJliell~ to express the trigonometric portion of the solutions sepannely as in tbe bottom of Table 9middot2
He~enyi (1946) developed equations for a load at any point along a beam (see Fig 9middot10b) mea~ured from the len end as rallows
JAN -20 00 (THU) 1018 BEl TEL415 768 4898 p 004005
412 FOlNDAT10N ANALYSIS NI) OESION
k = kiP Hncludes cffic or BJ
-----) -----0 cUM [b) Finite length beam cn elUlic
(oundation ---
--~----~gt~~-r--IJ~lt~--~~~M I ~~
Moment curve
Ii ---shy ~ Q ---~~
~ Shear curve
ta) Infillitc Icnlh beam an an elude rOllndatlan
FIGUDE 1)10 Beam on eillstic roundaticm
Y k~ (sinh ~l_ sjJl2 AL) 2 cosh AX cosu (sinh U cos la cosh)b
-ilin L cosh )(J cos lb) + (cosh It-X sin lx
+ sinh 1x cos tx) [sinh U (sin)a cosh 1b - cos ttl sinh lb)
+~j )L (sinh lQ cos)b - cosh ia sin Ah)J) (9middot12)
M a t ( hl ~ l AL) 2 sin AX sin h (sinh tL cos ~ cosb lb _ SIn I - SUI
- Sill U cosh AU WS ~iJ - l~osh 1( sinlx - sillh lx cos AX)
x [sinh)L (sin ta cosb 1b - cos )a sinh )b)
+sill )L sinh l cos ib - coshit sin ib)J (9-13)
-- TEL415 768 4898 JAN -20 OOTHUI 1018 BEl bull __ ~ bullbull nM~1gt UN ElAT1C rOU~tgtAIr)NS 411
x (sinh L cos AQ cosh Jb - sin iL cosh AQ CQS )h)
+ sinh Ax sin i( [sinh L (sin la cosh b shy cos 1Q sinh lb)
+ sin )L (liinh )a etlS h shy cosh AQ sin )b)]
The equation far the slope eof the beam at any point is not pre$ented is of little value in the design of a footing The value of x to use in the equa from the end o the beam to the point ror which the deOection moment or desired If x is less than the distance use the equations lS given and meaSUf x from C Ifx is largdf than a replace a with b in the equations and measure x from D (Fig 9middottOb) These equations may be rewritten as
Y=~A M=S and QPCk ~A
whllre the coeffioients A B and C are the values or the hyperbolic and trigonometric remainder of Eqs (9-12) to (9middot14)
It has been proposed that one could u~e U previously defined to determine if a foundation should be analyzed 011 the basis of the conventional rigid procedure Or as a beam on an elastic foundation
Rigi members (bending not influenced much by k)
(bending bcavity localized)
e 8l1tbor has found the above criteria 0 1 e app leation bocause of the infiuence or number of loads and their locations on the member
The classical solution presented here has several distinct disadviulluges over the finj[~middotelement solution presented i~ the next section such as
I Assumes weipoundhtless beam (but weight wUl be a factor when footing tends to stlparate from the soil)
2 Difficult to remove soil effect when footing tends to separate [rom soil 3 Difficult [0 account for boundary conditions orknown rotation or deflection at
seleCted points 4 Difficult to apply multiple types or loads to a foolina S Difficult to chanse footins properties of I D and B 6 Difficult to allow for change in subgrade reaclion along fOOling
Although tbe disltdvaruages are substantial iome engineeri prefer the classical beatll-onelaslic-foundation approacb over discrete element analyses Rarely the classical approach may be a better model than a discrete elemetn analysis so it is worthwhile to have access to ilii5 method of solution
P 005005
V 1 _ v
410 FouNDATION ANALVSlS AND DI5KlN
97 CLASSICAL SOLllTION OF BEAM ON ELASTIC FOlJNDAnON
When tlexur1 rigidity oCthe [aotin iii taken into accounl a solution is used that is based on some fonn of a heam on an elEl~tic (oundaLlon This may be of the classical Winkler solution of about 1861 in which the founchulon is considered as a bed of sprins (Winkler round ation) or a nnllgteement procedure of the nex section
The classical solutions being of closed ronn are not as ~ncra in application as the finite-clement merhod The basic differential equal ion is (see Fie 9-10)
pound1 dXlJy q - k~y (9-1l)
JAN -20 OO(THU) 1018
SPJ(IAL morlNOS owp BIlAS ON f)Imc ~(lIlNIgtIlTIONS 411
TABLE)2 Cloted-form Bolldons of infinite beam on Iseric fOlndlltiQn (Fig 9middot1011)
-VI M=TBu
Q -VIC
CflrJCllnrnltuli 101141 QI tilnln Moment III CDnllllf
MJl J -k- Bu dcllcclion
P M =rrcbullbull
-I -MeQ=-1gt Q= -2- A shear
Z
The A B C IiLPd D COtlfficienLS are
A =- o~) + silll)
BJgtt c-lmiddot ~in AX
Cl~ - middot(cosx - sin ltx)
1J1~ -u COampx
where k kB In solvin the equations a variable is inLroduced
bull 4 (iii )Iii -Jill or
TabJe 9middot2 Sives the closedmiddotfonn solution of t e basic differential equations for scveralloadingll shown in Fig 9-10 ulilizing the Winkler concept It is convCJliell~ to express the trigonometric portion of the solutions sepannely as in tbe bottom of Table 9middot2
He~enyi (1946) developed equations for a load at any point along a beam (see Fig 9middot10b) mea~ured from the len end as rallows
JAN -20 00 (THU) 1018 BEl TEL415 768 4898 p 004005
412 FOlNDAT10N ANALYSIS NI) OESION
k = kiP Hncludes cffic or BJ
-----) -----0 cUM [b) Finite length beam cn elUlic
(oundation ---
--~----~gt~~-r--IJ~lt~--~~~M I ~~
Moment curve
Ii ---shy ~ Q ---~~
~ Shear curve
ta) Infillitc Icnlh beam an an elude rOllndatlan
FIGUDE 1)10 Beam on eillstic roundaticm
Y k~ (sinh ~l_ sjJl2 AL) 2 cosh AX cosu (sinh U cos la cosh)b
-ilin L cosh )(J cos lb) + (cosh It-X sin lx
+ sinh 1x cos tx) [sinh U (sin)a cosh 1b - cos ttl sinh lb)
+~j )L (sinh lQ cos)b - cosh ia sin Ah)J) (9middot12)
M a t ( hl ~ l AL) 2 sin AX sin h (sinh tL cos ~ cosb lb _ SIn I - SUI
- Sill U cosh AU WS ~iJ - l~osh 1( sinlx - sillh lx cos AX)
x [sinh)L (sin ta cosb 1b - cos )a sinh )b)
+sill )L sinh l cos ib - coshit sin ib)J (9-13)
-- TEL415 768 4898 JAN -20 OOTHUI 1018 BEl bull __ ~ bullbull nM~1gt UN ElAT1C rOU~tgtAIr)NS 411
x (sinh L cos AQ cosh Jb - sin iL cosh AQ CQS )h)
+ sinh Ax sin i( [sinh L (sin la cosh b shy cos 1Q sinh lb)
+ sin )L (liinh )a etlS h shy cosh AQ sin )b)]
The equation far the slope eof the beam at any point is not pre$ented is of little value in the design of a footing The value of x to use in the equa from the end o the beam to the point ror which the deOection moment or desired If x is less than the distance use the equations lS given and meaSUf x from C Ifx is largdf than a replace a with b in the equations and measure x from D (Fig 9middottOb) These equations may be rewritten as
Y=~A M=S and QPCk ~A
whllre the coeffioients A B and C are the values or the hyperbolic and trigonometric remainder of Eqs (9-12) to (9middot14)
It has been proposed that one could u~e U previously defined to determine if a foundation should be analyzed 011 the basis of the conventional rigid procedure Or as a beam on an elastic foundation
Rigi members (bending not influenced much by k)
(bending bcavity localized)
e 8l1tbor has found the above criteria 0 1 e app leation bocause of the infiuence or number of loads and their locations on the member
The classical solution presented here has several distinct disadviulluges over the finj[~middotelement solution presented i~ the next section such as
I Assumes weipoundhtless beam (but weight wUl be a factor when footing tends to stlparate from the soil)
2 Difficult to remove soil effect when footing tends to separate [rom soil 3 Difficult [0 account for boundary conditions orknown rotation or deflection at
seleCted points 4 Difficult to apply multiple types or loads to a foolina S Difficult to chanse footins properties of I D and B 6 Difficult to allow for change in subgrade reaclion along fOOling
Although tbe disltdvaruages are substantial iome engineeri prefer the classical beatll-onelaslic-foundation approacb over discrete element analyses Rarely the classical approach may be a better model than a discrete elemetn analysis so it is worthwhile to have access to ilii5 method of solution
P 005005
JAN -20 OO(THU) 1018
SPJ(IAL morlNOS owp BIlAS ON f)Imc ~(lIlNIgtIlTIONS 411
TABLE)2 Cloted-form Bolldons of infinite beam on Iseric fOlndlltiQn (Fig 9middot1011)
-VI M=TBu
Q -VIC
CflrJCllnrnltuli 101141 QI tilnln Moment III CDnllllf
MJl J -k- Bu dcllcclion
P M =rrcbullbull
-I -MeQ=-1gt Q= -2- A shear
Z
The A B C IiLPd D COtlfficienLS are
A =- o~) + silll)
BJgtt c-lmiddot ~in AX
Cl~ - middot(cosx - sin ltx)
1J1~ -u COampx
where k kB In solvin the equations a variable is inLroduced
bull 4 (iii )Iii -Jill or
TabJe 9middot2 Sives the closedmiddotfonn solution of t e basic differential equations for scveralloadingll shown in Fig 9-10 ulilizing the Winkler concept It is convCJliell~ to express the trigonometric portion of the solutions sepannely as in tbe bottom of Table 9middot2
He~enyi (1946) developed equations for a load at any point along a beam (see Fig 9middot10b) mea~ured from the len end as rallows
JAN -20 00 (THU) 1018 BEl TEL415 768 4898 p 004005
412 FOlNDAT10N ANALYSIS NI) OESION
k = kiP Hncludes cffic or BJ
-----) -----0 cUM [b) Finite length beam cn elUlic
(oundation ---
--~----~gt~~-r--IJ~lt~--~~~M I ~~
Moment curve
Ii ---shy ~ Q ---~~
~ Shear curve
ta) Infillitc Icnlh beam an an elude rOllndatlan
FIGUDE 1)10 Beam on eillstic roundaticm
Y k~ (sinh ~l_ sjJl2 AL) 2 cosh AX cosu (sinh U cos la cosh)b
-ilin L cosh )(J cos lb) + (cosh It-X sin lx
+ sinh 1x cos tx) [sinh U (sin)a cosh 1b - cos ttl sinh lb)
+~j )L (sinh lQ cos)b - cosh ia sin Ah)J) (9middot12)
M a t ( hl ~ l AL) 2 sin AX sin h (sinh tL cos ~ cosb lb _ SIn I - SUI
- Sill U cosh AU WS ~iJ - l~osh 1( sinlx - sillh lx cos AX)
x [sinh)L (sin ta cosb 1b - cos )a sinh )b)
+sill )L sinh l cos ib - coshit sin ib)J (9-13)
-- TEL415 768 4898 JAN -20 OOTHUI 1018 BEl bull __ ~ bullbull nM~1gt UN ElAT1C rOU~tgtAIr)NS 411
x (sinh L cos AQ cosh Jb - sin iL cosh AQ CQS )h)
+ sinh Ax sin i( [sinh L (sin la cosh b shy cos 1Q sinh lb)
+ sin )L (liinh )a etlS h shy cosh AQ sin )b)]
The equation far the slope eof the beam at any point is not pre$ented is of little value in the design of a footing The value of x to use in the equa from the end o the beam to the point ror which the deOection moment or desired If x is less than the distance use the equations lS given and meaSUf x from C Ifx is largdf than a replace a with b in the equations and measure x from D (Fig 9middottOb) These equations may be rewritten as
Y=~A M=S and QPCk ~A
whllre the coeffioients A B and C are the values or the hyperbolic and trigonometric remainder of Eqs (9-12) to (9middot14)
It has been proposed that one could u~e U previously defined to determine if a foundation should be analyzed 011 the basis of the conventional rigid procedure Or as a beam on an elastic foundation
Rigi members (bending not influenced much by k)
(bending bcavity localized)
e 8l1tbor has found the above criteria 0 1 e app leation bocause of the infiuence or number of loads and their locations on the member
The classical solution presented here has several distinct disadviulluges over the finj[~middotelement solution presented i~ the next section such as
I Assumes weipoundhtless beam (but weight wUl be a factor when footing tends to stlparate from the soil)
2 Difficult to remove soil effect when footing tends to separate [rom soil 3 Difficult [0 account for boundary conditions orknown rotation or deflection at
seleCted points 4 Difficult to apply multiple types or loads to a foolina S Difficult to chanse footins properties of I D and B 6 Difficult to allow for change in subgrade reaclion along fOOling
Although tbe disltdvaruages are substantial iome engineeri prefer the classical beatll-onelaslic-foundation approacb over discrete element analyses Rarely the classical approach may be a better model than a discrete elemetn analysis so it is worthwhile to have access to ilii5 method of solution
P 005005
JAN -20 00 (THU) 1018 BEl TEL415 768 4898 p 004005
412 FOlNDAT10N ANALYSIS NI) OESION
k = kiP Hncludes cffic or BJ
-----) -----0 cUM [b) Finite length beam cn elUlic
(oundation ---
--~----~gt~~-r--IJ~lt~--~~~M I ~~
Moment curve
Ii ---shy ~ Q ---~~
~ Shear curve
ta) Infillitc Icnlh beam an an elude rOllndatlan
FIGUDE 1)10 Beam on eillstic roundaticm
Y k~ (sinh ~l_ sjJl2 AL) 2 cosh AX cosu (sinh U cos la cosh)b
-ilin L cosh )(J cos lb) + (cosh It-X sin lx
+ sinh 1x cos tx) [sinh U (sin)a cosh 1b - cos ttl sinh lb)
+~j )L (sinh lQ cos)b - cosh ia sin Ah)J) (9middot12)
M a t ( hl ~ l AL) 2 sin AX sin h (sinh tL cos ~ cosb lb _ SIn I - SUI
- Sill U cosh AU WS ~iJ - l~osh 1( sinlx - sillh lx cos AX)
x [sinh)L (sin ta cosb 1b - cos )a sinh )b)
+sill )L sinh l cos ib - coshit sin ib)J (9-13)
-- TEL415 768 4898 JAN -20 OOTHUI 1018 BEl bull __ ~ bullbull nM~1gt UN ElAT1C rOU~tgtAIr)NS 411
x (sinh L cos AQ cosh Jb - sin iL cosh AQ CQS )h)
+ sinh Ax sin i( [sinh L (sin la cosh b shy cos 1Q sinh lb)
+ sin )L (liinh )a etlS h shy cosh AQ sin )b)]
The equation far the slope eof the beam at any point is not pre$ented is of little value in the design of a footing The value of x to use in the equa from the end o the beam to the point ror which the deOection moment or desired If x is less than the distance use the equations lS given and meaSUf x from C Ifx is largdf than a replace a with b in the equations and measure x from D (Fig 9middottOb) These equations may be rewritten as
Y=~A M=S and QPCk ~A
whllre the coeffioients A B and C are the values or the hyperbolic and trigonometric remainder of Eqs (9-12) to (9middot14)
It has been proposed that one could u~e U previously defined to determine if a foundation should be analyzed 011 the basis of the conventional rigid procedure Or as a beam on an elastic foundation
Rigi members (bending not influenced much by k)
(bending bcavity localized)
e 8l1tbor has found the above criteria 0 1 e app leation bocause of the infiuence or number of loads and their locations on the member
The classical solution presented here has several distinct disadviulluges over the finj[~middotelement solution presented i~ the next section such as
I Assumes weipoundhtless beam (but weight wUl be a factor when footing tends to stlparate from the soil)
2 Difficult to remove soil effect when footing tends to separate [rom soil 3 Difficult [0 account for boundary conditions orknown rotation or deflection at
seleCted points 4 Difficult to apply multiple types or loads to a foolina S Difficult to chanse footins properties of I D and B 6 Difficult to allow for change in subgrade reaclion along fOOling
Although tbe disltdvaruages are substantial iome engineeri prefer the classical beatll-onelaslic-foundation approacb over discrete element analyses Rarely the classical approach may be a better model than a discrete elemetn analysis so it is worthwhile to have access to ilii5 method of solution
P 005005
-- TEL415 768 4898 JAN -20 OOTHUI 1018 BEl bull __ ~ bullbull nM~1gt UN ElAT1C rOU~tgtAIr)NS 411
x (sinh L cos AQ cosh Jb - sin iL cosh AQ CQS )h)
+ sinh Ax sin i( [sinh L (sin la cosh b shy cos 1Q sinh lb)
+ sin )L (liinh )a etlS h shy cosh AQ sin )b)]
The equation far the slope eof the beam at any point is not pre$ented is of little value in the design of a footing The value of x to use in the equa from the end o the beam to the point ror which the deOection moment or desired If x is less than the distance use the equations lS given and meaSUf x from C Ifx is largdf than a replace a with b in the equations and measure x from D (Fig 9middottOb) These equations may be rewritten as
Y=~A M=S and QPCk ~A
whllre the coeffioients A B and C are the values or the hyperbolic and trigonometric remainder of Eqs (9-12) to (9middot14)
It has been proposed that one could u~e U previously defined to determine if a foundation should be analyzed 011 the basis of the conventional rigid procedure Or as a beam on an elastic foundation
Rigi members (bending not influenced much by k)
(bending bcavity localized)
e 8l1tbor has found the above criteria 0 1 e app leation bocause of the infiuence or number of loads and their locations on the member
The classical solution presented here has several distinct disadviulluges over the finj[~middotelement solution presented i~ the next section such as
I Assumes weipoundhtless beam (but weight wUl be a factor when footing tends to stlparate from the soil)
2 Difficult to remove soil effect when footing tends to separate [rom soil 3 Difficult [0 account for boundary conditions orknown rotation or deflection at
seleCted points 4 Difficult to apply multiple types or loads to a foolina S Difficult to chanse footins properties of I D and B 6 Difficult to allow for change in subgrade reaclion along fOOling
Although tbe disltdvaruages are substantial iome engineeri prefer the classical beatll-onelaslic-foundation approacb over discrete element analyses Rarely the classical approach may be a better model than a discrete elemetn analysis so it is worthwhile to have access to ilii5 method of solution
P 005005